S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-AO drawing an adverse inference without providing an opportunity to explain the working of allocation is in violation of principals of natural justice. [S. 144C]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Payment made to non-resident for maintenance of a project under a service agreement-recomputation of Arm’s length price-held, claim by the assessee genuine as no such computation was done for previous years.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-When assessee was able to prove the difference in price was due to quality of products sold, no transfer pricing adjustment was warranted.[S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Prices of comparable products on their respective invoice/shipment date as considered in customs valuation would yield a more reliable result in absence of any differences arising out of contract terms and product quality.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Adhoc addition made by the Transfer Pricing Officer on account of ‘Price Penetration Adjustment’ by the assessee, treating the same as income is without jurisdiction.[S. 92, 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-(i) Insurance claim and foreign exchange fluctuation gain related to raw material consumed by assessee in operation of business is to be added to operating revenue of assessee to arrive at ALP of international transaction. (ii) Adjustment of PLI of comparables should be made at transaction level and not entity level. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-No further adjustment required of interest on outstanding receivables where working capital adjustment takes the same into account while benchmarking the main international transaction.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Most appropriate method-Acquisition of bundle of sports broadcasting rights-No comparable uncontrolled transaction prices available-Unique intangible asset-“other method” more appropriate. [S.92]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Purchases From AE-Sales By AE To Non-Related Parties-In one Month at price significantly higher than in other months-Difference in prices due to qualitative difference between ingots sold by AE to assessee and those sold to third parties-Substantial evidence to prove quality of products sold-No rationale in making adjustment only for one month-Reversal of adjustment is proper. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Selection of comparable-Turnover filter-Turnover of assessee 332 crores-DRP is justified in directing turnover of 200 crores to 2000 crores-Multiple of 10 times turnover could not be adopted. [S.92CA]