Dismissing the appeal of the revenue the Court held that; Mere dissatisfaction with the findings of facts arrived at by the Tribunal is not a substantial question of law. ( AY.2005 -06)
PCIT v. Cypress Semiconductors Technology India Pvt. Ltd. (2018) 408 ITR 531 (Karn.)(HC)
S. 92C : Transfer pricing-Comparable-Mere dissatisfaction with the findings of facts arrived at by the Tribunal is not a substantial question of law – Appeal was dismissed.[S. 260A]