Held that when the Revenue accepted the transactional net margin method in respect of the sales and purchases, and the comparable uncontrolled price method in respect of the interest received on loans and reimbursement of expenses, the writing off of these two amounts was subsumed in the transactions of receipt of interest on loans, and did not necessitate any separate benchmarking. The addition made on account of the writing off by the assessee of the dues and bad debts from the Russian subsidiary were not sustainable. (AY. 2009-10)
Aurobindo Pharma Ltd. v. Dy. CIT (2022) 98 ITR 54 (SN)(Hyd) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Net Margin Method-Comparable Uncontrolled Price Methods-Bad debts-Written off-Write off does not affect the Arm’s length price. [S. 36(1)(vii)]