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    <description>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&#039;s factual determinations were left undisturbed.</description>
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