TP disputes on Comparables & Filter selection are not substantial question of law

Pr. CIT Vs M/s. Softbrands India P. Ltd. (Karnataka High Court) Facts of the case: The assessee was engaged in providing software services to its associated enterprise (AE). During the assessment year, it earned an operating profit of 8.33% on cost. The assessee applied Comparable Uncontrolled Price (CUP) method for substantiating arm’s length price (ALP) of its international transactions. Transfer Pricing officer (TPO) rejected CUP method and applied Transactional Net Margin Method (TNMM). The TPO used a set of 20 comparables and determined ALP at cost plus 20.68%, which after giving effec...