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 an

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