High Court allowed the assessee’s appeal holding that the Transfer Pricing Officer having accepted the transactional net margin method as the most appropriate method could not have applied the comparable uncontrolled price method for only one element of the international transaction of payment of royalty, that even after the new agreement was entered into by the assessee. Held, dismissing the petition, that sufficient cause and grounds had not been made out to condone the delay in filing the petition.(AY. 2015-16 to 2017-18)
ACIT v. Cummins India Ltd.(2025) 476 ITR 158 /304 Taxman 604 (SC) Editorial : Cummins India Ltd. v. ACIT (2023) 294 Taxman 619/ 335 CTR 387 / (2024) 470 ITR 184 (Bom)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Royalty-Most appropriate method-SLP of revenue dismissed. [Art. 136]
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