Transfer pricing comparables and receivables interest adjustment failed where precedent and factual findings left no substantial question of law.

Transfer pricing comparables were not interfered with because the issue was already covered by the Court's earlier decision in the assessee's own case. The proposed adjustment for interest on receivables also failed because the Tribunal found, on facts, that the assessee was debt-free and no receivables-based interest issue arose. In both respects, the Revenue's challenge did not raise any substantial question of law, so the Tribunal's order remained undisturbed.

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Issues: (i) Whether the direction regarding inclusion and exclusion of comparable companies for transfer pricing analysis required interference. (ii) Whether any substantial question of law arose on the proposed adjustment for interest on receivables.

Issue (i): Whether the direction regarding inclusion and exclusion of comparable companies for transfer pricing analysis required interference.

Analysis: The question was treated as covered by the Court's earlier decision in the assessee's own case for the relevant comparable assessment years.

Conclusion: The issue was answered against the Revenue and no interference was called for.

Issue (ii): Whether any substantial question of law arose on the proposed adjustment for interest on receivables.

Analysis: The Tribunal had recorded a factual finding that the assessee was a debt-free company and that no question of receiving interest on receivables arose.

Conclusion: No substantial question of law arose on this issue and the Revenue's challenge failed.

Final Conclusion: The appeal did not succeed and the Tribunal's order was left undisturbed.

Ratio Decidendi: Where the transfer pricing issue is already covered by binding precedent and the challenged adjustment turns only on a factual finding that no receivables-based interest issue arises, no substantial question of law arises under section 260A.

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