S. 92C : Transfer pricing – Arms’ length price – Selection of comparables -Finding of fact by Tribunal that (i) the activities of the assessee and comparables are functionally different(ii) the extraordinary events such as merger/amalgamation would have an impact/effect on the profitability of comparable (iii) merely because both assessee and the comparable provide ITES services they do not become comparable, cannot be interfered, more particularly in the absence of the same being shown to be perverse-No question of law. [S. 260A]