Transfer pricing comparables and remand directions raised no substantial question of law, leaving the Revenue's appeals unexamined on merits.

The Delhi HC considered whether Revenue appeals in transfer pricing matters disclosed any substantial question of law arising from the ITAT's inclusion and exclusion of comparables and its remand of certain comparables to the TPO for arm's length price determination. The Court held that the impugned orders did not raise any substantial question of law warranting appellate interference. As a result, the Revenue's challenge failed and the appeals were not entertained on merits.

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Issues: Whether the Revenue's appeals raised any substantial question of law in relation to the ITAT's inclusion and exclusion of comparables and remand of certain comparables to the TPO for determination of arm's length price in transfer pricing matters.

Analysis: The appeals challenged the ITAT's approach to comparable selection and remand directions concerning determination of arm's length price in respect of international transactions. The Court found that the impugned orders did not disclose any substantial question of law warranting interference in appeal.

Conclusion: The issue was answered against the Revenue and in favour of the assessee; the appeals were not entertained on merits.

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