https://www.taxtmi.com/caselaws?id=797319 Selection of the Most Appropriate Method for transfer-pricing benchmarking, including preference for the Transactional Net Margin Method over the Comparable Uncontrolled Price Method, is generally a factual determination. Intervention under section 260A is not warranted merely because of differing views on method selection or related economic and pricing adjustments, unless findings are perverse or conflict with Rules 10B and 10C. Where documentary material supports the factual findings, consequential transfer-pricing adjustments remain incidental to the method-selection issue and do not independently raise a substantial question of law. en-us Mon, 10 Aug 2026 00:00:00 +0530 Thu, 20 Aug 2026 08:14:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797319 Selection of the Most Appropriate Method for transfer-pricing benchmarking, including preference for the Transactional Net Margin Method over the Comparable Uncontrolled Price Method, is generally a factual determination. Intervention under section 260A is not warranted merely because of differing views on method selection or related economic and pricing adjustments, unless findings are perverse or conflict with Rules 10B and 10C. Where documentary material supports the factual findings, consequential transfer-pricing adjustments remain incidental to the method-selection issue and do not independently raise a substantial question of law. Case-Laws Income Tax Mon, 10 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797319