Transfer pricing findings are largely factual, so mere disagreement does not create a substantial question of law.

Interference under section 260A of the Income-tax Act is confined to cases involving a substantial question of law, and transfer pricing issues such as selection of comparables, application of filters and arm's length price determination are ordinarily factual. Mere disagreement with the Tribunal's findings does not justify appellate interference unless ex facie perversity is shown. On the stated facts, no substantial question of law arose, so the appeal could not be maintained on merits under section 260A.

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Issues: Whether the appeal under section 260A of the Income-tax Act, 1961 gave rise to any substantial question of law in a transfer pricing dispute concerning selection of comparables and related findings of the Tribunal.

Analysis: The Court followed the principle that interference under section 260A is warranted only when a substantial question of law arises, and not merely because a party disputes the Tribunal's factual conclusions on transfer pricing matters. It noted that questions relating to selection of comparables, application of filters, and determination of arm's length price are predominantly factual. In the absence of any ex facie perversity in the Tribunal's findings, no substantial question of law could be said to arise for consideration.

Conclusion: No substantial question of law arose and the appeal was not maintainable on merits under section 260A.

Ratio Decidendi: Mere dissatisfaction with the Tribunal's factual findings in transfer pricing matters, including selection of comparables and filters, does not by itself give rise to a substantial question of law under section 260A of the Income-tax Act, 1961.

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