The High Court held that where the Tribunal had only remanded the case to the file of the TPO to examine the comparability of a company, no substantial question of law can be said to arise in challenging such a finding. It was further held that KPO was a type of BPO, therefore, under a TNMM analysis, the two could not be said to be completely different. It was further held that selection of comparables is largely a fact driven exercise and the conclusions of the Tribunal in this regard should generally be considered final. (AY. 2011-12)