The assessee was engaged in international transactions with its associated enterprises. The TPO had adopted certain comparables for determining ALP, which the Tribunal rejected after detailed factual analysis. The Revenue filed appeal contending substantial question of law arose. The High Court held that once the Tribunal’s findings were based on factual analysis, no question of law arose.
PCIT v. Warburg Pincus India (P.) Ltd. [2023] 153 taxmann.com 574 (Bom)(HC) Editorial : On SLP by revenue, Supreme Court PCIT v. Warburg Pincus India (P.) Ltd [2023] 295 Taxman 417 (SC) set aside High Court order and remanded for fresh consideration.
S. 92C : Transfer pricing-Arm’s length price-Tribunal after giving detailed reasons rejected comparables selected by TPO-No question of law arose for consideration. [S. 260A]