| COURT: | ITAT Mumbai |
| CORAM: | R. C. Sharma (AM), Vivek Varma (JM) |
| SECTION(S): | 92CA |
| GENRE: | Transfer Pricing |
| CATCH WORDS: | location savings adjustment, risk adjustment, Transfer Pricing |
| COUNSEL: | Karishma R Phatarphekar |
| DATE: | January 9, 2015 (Date of pronouncement) |
| DATE: | January 12, 2015 (Date of publication) |
| AY: | 2009-10 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| Transfer Pricing: Law on making adjustments for 'risk' and 'location savings' explained | |
The arm’s length principle requires benchmarking to be done with comparables in the jurisdiction of tested party and the location savings, if any, would be reflected in the profitability earned by comparables which are used for benchmarking the international transactions. Thus in our view, no separate/additional allocation is called for on account of location savings
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