https://www.taxtmi.com/caselaws?id=364107 Transfer pricing disputes over selection of comparables, application of filters, and arm's length price are ordinarily findings of fact, so no substantial question of law arises under section 260-A absent demonstrable ex facie perversity. The Tribunal's reference to section 10A was only obiter and caused no legal prejudice because the assessment order had not allowed any deduction on the transfer pricing adjustment under that provision. The second proviso to section 92C(4) did not change the result on the facts. Accordingly, the Revenue's appeal was not maintainable on the transfer pricing issues. en-us Tue, 10 Jul 2018 00:00:00 +0530 Mon, 23 Jul 2018 08:14:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=364107 Transfer pricing disputes over selection of comparables, application of filters, and arm's length price are ordinarily findings of fact, so no substantial question of law arises under section 260-A absent demonstrable ex facie perversity. The Tribunal's reference to section 10A was only obiter and caused no legal prejudice because the assessment order had not allowed any deduction on the transfer pricing adjustment under that provision. The second proviso to section 92C(4) did not change the result on the facts. Accordingly, the Revenue's appeal was not maintainable on the transfer pricing issues. Case-Laws Income Tax Tue, 10 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=364107