PCIT v. Broadcom India Pvt. Ltd. (2019) 415 ITR 380 (Karn.)(HC)

S. 92C : Transfer pricing–Arm’s length price–Comparable-Unless ex facie perversity in the findings of the Tribunal is established-Appeal is not maintainable.[S. 260A]

Court held that an appeal can be made to the High Court only on a substantial question of law. In an international transaction the determination of the arm’s length price is a question of fact. Unless ex facie perversity in the findings of the Tribunal is established by the appellant, the appeal at the instance of an assessee or the Revenue under section 260A of the Act is not maintainable. (AY. 2006-07)