Court held that the determination of arm’s length price in international transactions is a finding of fact. No substantial question of law arises unless the finding is perverse. (AY. 2009-10)
PCIT v. Ipass India P. Ltd. (2019] 414 ITR 662 (Karn.)(HC)
S. 92C : Transfer pricing-Arm’s Length Price-Question of fact–No substantial question of law.[S. 260A]