https://www.taxtmi.com/caselaws?id=799310 Section 260-A permits an appeal only where a substantial question of law arises. For transfer-pricing determination of the arm's length price of research and development services, functional comparability was undisputed. Exclusion of Neeman Medical International (Asia) Limited rested only on an assertion of consistent losses, but the financial material did not establish a consistently loss-making position. Its inclusion as a functionally comparable entity therefore did not raise a substantial question of law. en-us Tue, 08 Sep 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799310 Section 260-A permits an appeal only where a substantial question of law arises. For transfer-pricing determination of the arm's length price of research and development services, functional comparability was undisputed. Exclusion of Neeman Medical International (Asia) Limited rested only on an assertion of consistent losses, but the financial material did not establish a consistently loss-making position. Its inclusion as a functionally comparable entity therefore did not raise a substantial question of law. Case-Laws Income Tax Tue, 08 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799310