https://www.taxtmi.com/caselaws?id=365045 Under Section 260A, an appeal lies only where a substantial question of law arises. In the transfer pricing context, the selection and acceptance of comparables under the TNMM was treated as a factual exercise based on functional profile and record material. The High Court noted that the Tribunal had examined functional similarity and the relevance of the comparable's material cost before reaching its conclusion. Because the dispute turned on concurrent factual findings and no substantial question of law was shown, the Court declined to interfere and the revenue's appeal was dismissed. en-us Tue, 10 Jul 2018 00:00:00 +0530 Sat, 09 Feb 2019 08:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=365045 Under Section 260A, an appeal lies only where a substantial question of law arises. In the transfer pricing context, the selection and acceptance of comparables under the TNMM was treated as a factual exercise based on functional profile and record material. The High Court noted that the Tribunal had examined functional similarity and the relevance of the comparable's material cost before reaching its conclusion. Because the dispute turned on concurrent factual findings and no substantial question of law was shown, the Court declined to interfere and the revenue's appeal was dismissed. Case-Laws Income Tax Tue, 10 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=365045