Dismissing the appeal the Court held that difference of opinion between the parties, as to the appropriateness of one or the other methods to calculate the arm’s length price, cannot per se be a ground for interference and the appropriateness of the method unless shown to be contrary to the Income-tax Rules, 1962, specially rules 10B and 10C are not issues that ought to be gone into under section 260A of the Act.(AY.2008-09)