S. 92C : Transfer pricing-Arm’s length price-Technical assistance fee-Rule of consistency-Adjustment was deleted. [S.92A]

S. 92C : Transfer pricing-Arm’s length price-Management fees-Followed order of earlier year-Addition was deleted [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price of guarantee commission-Arm’s length guarantee commission charge should be restricted at 0.5% .

S. 92C : Transfer pricing-Arm’s length price-TPO did not give any analysis to demonstrate how purchase of any material by eligible units from non-eligible units could have yielded extra profits-No downward adjustment of profit of eligible units (S. 80-IA(10)

S. 92C : Transfer pricing-Arm’s length price of guarantee commission-Arm’s length guarantee commission charge should be restricted at 0.5%

S. 92C : Transfer pricing-Arm’s length price-Transfer pricing adjustment should be restricted only to international transactions and not at entity level [Rule. 10AB]

S. 92C : Transfer pricing-Arm’s length price-Provision for bad debts to be treated as non-operating expenditure for purpose of computing profitability under transfer pricing provisions-Companies having bad debt should be considered in final set of comparables-Remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment-Question of adjustment on negative working capital does not arise-Selection of comparables-Companies engaged in diversified activities and earning revenue from various activities and no segmental data available, companies not passing employee cost filter, cannot be taken as comparable-On facts rejection of rental expenses is held to be proper. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Royalty-Transactions valued at nil ignoring evidence brought on record-Transfer pricing adjustment not sustainable.[S.92CA(3)]

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment permissible for better comparability [S.92CA, R. 10B(1)(e) (iii)]