S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Assessee in the business of ship chartering services-Rules required Transactional Net Margin Method with respect to net profit margin-Assessee using internal comparables with associated enterprises-Incorrect approach-Revenue authority justified in rejecting methodology. [R. 10B(1)(e)]

S. 92C : Transfer pricing-Arm’s length price-Fee for Corporate guarantee from associated enterprise-Source of TPO for figuring out that assessee issued corporate guarantee not clear-Additions deleted by CIT (A) is justified. [S.92CA]

S. 92C: Transfer pricing-Arm’s length price-Comparable uncontrolled price method-Interest earned on loan to associated enterprise-Justified in deleting addition. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software development and services and Information Technology–Outsourcing model of business–Company merged with two other companies, growth of revenue increased-Not to included in the list of comparables.

S. 92C : Transfer pricing-Arm’s length price-Manufacture and assembly-Comparable-Company passed turnover filter but fails to pass functional analysis-Department’s appeal to remand the matter not justified and entertained-Addition was deleted [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Aggregation- Aggregation is not a rule of blind application and it is to be applied in certain situations and there has to be a scientific or rational basis for adoption; unless characteristic of ‘closely-linked’ is satisfied, aggregation is not possible-Matter remanded.

S. 92C : Transfer pricing-Arm’s length-Commercial expediency of expenditure-No separate adjustment is required to be made.

S. 92C : Transfer pricing-Arm’s length price-Technical assistance received-Order of CIT (A) giving relief was not challenged-Addition was deleted.

S. 92C : Transfer pricing-Arm’s length price-Adjustmnet of management fee-Disallowed under section 40(a)(i)-Disllaowing the same for Transfer pricing adjustment will lead to taxing the same amount twice-Addition was deleted.[S. 40(a)(i), 154]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Negative margin-Comaprable-Segmental details relating to various segments were not available–Sale of software license-Segmental details relating to revenue earned were not discernible-Could not be selected as comparable. [S. 92CA]