S. 92C : Transfer pricing-Arm’s length price-Comparable–Company having huge turnover and high profit margin and owning intangible intellectual property rights-Companies to be excluded-Company satisfying export turnover-To be included-Business process outsourcing activity”-Companies to be included-Working capital adjustment-Matter remanded. [S.92D R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Matter remanded. [S. 92D]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Companies whose turnover more than Rs. 200 Crores cannot be taken as comparable-Working capital adjustment-Matter remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Operating costs-Reimbursement of certain costs from Associated Enterprises-No Adjustment of markup on Assessee’s claim of pass-through cost. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Functionally dissimilar-Huge turnover and a giant company-Extrodinary events-Excluded from final list of comparable companies-Deferred trade receivables constitute International Transaction-Rate of Libor at six months + 400 basis points adopted by TPO was without any basis-Matter remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Sale of ophthalmic surgical electronic equipment, intraocular lenses, spare parts and pharmaceutical products.-Advertisement, marketing and sales promotion expenses-Bright Line Test-Expenditure incurred cannot be treated as International Transaction-Addition was deleted-Comparable-Functionally different companies cannot be taken as comparables. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Loss making companies-Losses incurred in only one year-Companies can be included-Financial statements of companies from public domain-Matter remanded-Functionally different-Equipment Different from a component manufacturing company-Cannot be compared-Working capital adjustment-Additional evidence-Matter remanded-Adjustment is restricted to International transaction with Associated enterprise [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover more than Rs.200 crores-Excluded-Working capital adjustment. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Restricted only to the international transactions-VRS expenses-Similar cost incurred by the comparables if any also be given. [S.37(1), 92CA]

S. 92C : Transfer pricing-Arm’s length price-Providing Crew for Employment on Principal’s Vessels-Agency fee-Expenses incurred reimbursed by associated enterprise-Adjustment was made based on incorrect appreciation of facts-Adjustment was deleted.[S. 144C]