Transfer pricing fact-finding on comparable companies upheld where no perversity or substantial question of law was shown.

The Telangana HC declined to interfere with the Tribunal's transfer pricing findings on the acceptability and non-acceptability of comparable companies. In the absence of any allegation of perversity or material showing that the factual findings were unsupported by evidence, the Court refused to substitute its own appreciation of the record. The Court also found no substantial question of law arising from the Tribunal's fact-finding and therefore rejected the request for remand for fresh consideration.

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Issues: Whether the Court should interfere with the Tribunal's fact-finding on rejection of comparable companies and remand for fresh consideration in the transfer pricing matter.

Analysis: The Tribunal had rendered findings on the acceptability and non-acceptability of the comparable companies. The Court found no allegation of perversity and no material to show that the findings were unsupported by evidence. In the absence of any substantial question of law, the Court declined to substitute its own appreciation of facts.

Conclusion: The Court declined to interfere with the Tribunal's order and held that no question of law arose for determination.

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