S. 92C : Transfer pricing-Arm’s length price-Comparble-Customised software development on contractual basis Job placement portal and BPO services-Dissimilarity in functions and for want of segmental accounts-Sponsorship fees and other expenses, said company was to be excluded from final set of comparables-Turnover more than 750 time cannot be considered as comparable-Profit margin-Sale of licence-Sale of software and products.
S. 92C : Transfer pricing-Arm’s length price-Software development-Directed to pass speaking order-Working capital-computed by taking actual data without putting any upper limit-Ad-hoc estimate of risk differential was directed to recompute. [S. 144C]
S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally different-Companies having turn over of 10 times greater cannot be considered as comparable companies.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Software development-Size and economies of scale/high risk companies-Functionally different-providing Information Technology Enabled Services (ITES) To be excluded from final list of comparables-Working capital adjustment was directed to be allowed on actual basis.
S. 92C : Transfer pricing-Arm’s length price-AMP expenses-TPO cannot be debarred from examining said international transaction with respect to arm’s length price.[S. 92B]
S. 92C : Transfer pricing-Arm’s length price-Addition of 10 percent-Allocation of expenses-Held to be not justified.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Tested party-Cost Plus Method (CPM)-Audit of segmental accounts-Cannot be rejected on the ground that the Accounts of overseas entities were not audited.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Matter remanded to the TPO-Turnover cap-Goodwill-Loss making companies-Size and Economies of Sale/High Risk Companies.
S. 92C : Transfer pricing-Arm’s length price-ITES services did not form a single composite transaction-Transactions cannot be aggregated-Extended credit period-Addition of notional interest is held to be not justified.
S. 92C : Transfer pricing-Arm’s length price-Loan and advance-Interest-CUP method-Reimbursement of expenses-No adjustment can be made-Corporate guarantee was extended by assessee as a shareholder activity-No adjustment can be made. [S. 92B]