Transfer pricing comparables rejected on factual comparability findings; no substantial question of law arose.

The Tribunal rejected the Transfer Pricing Officer's comparables, including SEEPZ-based entities and other selected companies, after recording detailed reasons that they were not proper comparables for arm's length price analysis. The determination rested on appreciation of facts and comparability assessment, rather than on any unsettled legal principle. The Bombay High Court noted that the Tribunal's view was a finding of fact and held that no substantial question of law arose.

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Issues: Whether the Tribunal was justified in rejecting the Transfer Pricing Officer's comparables and in confirming the assessee's computation of arm's length price.

Analysis: The Tribunal had recorded detailed and cogent reasons for holding that the comparables situated at SEEPZ, as well as the other companies selected by the Transfer Pricing Officer, could not be treated as proper comparables. The conclusion reached by the Tribunal was founded on appreciation of facts and the assessment of comparability.

Conclusion: The Tribunal's view involved a finding of fact and no substantial question of law arose.

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