Transfer pricing comparables and filters are factual matters, and no substantial question of law arose on appeal.

In an appeal under Section 260-A of the Income-tax Act arising from transfer pricing adjustments, the selection or exclusion of comparables and the application of filters such as related party transactions and turnover were treated as matters of factual appreciation. The Tribunal was described as the final fact-finding authority, and interference is available only where a substantial question of law arises or the findings are shown to be perverse, unsupported by evidence, or marked by non-application of mind. As no such perversity was demonstrated, the proposed issues were held not to raise substantial questions of law and the Tribunal's factual determinations were left undisturbed.

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Issues: Whether, in an appeal under Section 260-A of the Income-tax Act, 1961 arising from transfer pricing adjustments, the selection or exclusion of comparables and the application of filters such as related party transactions and turnover can give rise to a substantial question of law.

Analysis: The appeals concerned only the Tribunal's fact-based exercise of comparing companies, applying filters, and determining arm's length price. The Court held that Section 260-A permits interference only where a substantial question of law arises, and that the Tribunal remains the final fact-finding authority. Questions about whether a particular comparable is functionally similar, whether a filter was properly applied, or whether certain companies should be included or excluded are matters of factual appreciation. Such findings can be interfered with only if they are shown to be perverse, based on no evidence, or marked by total non-application of mind. No such perversity was demonstrated.

Conclusion: The proposed questions did not amount to substantial questions of law, and the Court declined to interfere with the Tribunal's factual determinations.

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