Tribunal held that where arm’s length value of transactions as computed by TPO was within permitted range of variation of +/- 5 per cent of actual value of transaction, downward adjustment made by TPO was not justified. (AY. 2008 -09)
Bata India Ltd. v. DCIT (2020) 180 ITD 464 (Kol) (Trib.)
S. 92B : Transfer pricing – Safe Harbour Rules (5 per cent variation) – No TP adjustment could be made where arm’s length value of transactions as computed by TPO was within permitted range of variation of +/- 5 per cent of actual value of transaction. [ S.92C ]