Section 92C of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — The Tribunal after elaborately analyzing the record and appreciating the factual matrix excluded the comparables from the set of comparables on the ground that they were engaged in different verticals and worked through outsourcing models, thus, being functionally different could not be considered as comparable to the assessee company and the revenue was unable to demonstrate that the order of the Tribunal suffered from any illegality or perversity on the ground that it had failed to consider or appreciate any relevant circumstance for excluding  comparables — Principal Commissioner of income tax vs. Corporate Executive Board India P. Ltd. [2020] 420 ITR 52 (P&H)