S. 92C : Transfer pricing-Arm’s length price-Having high turnover-Turnover is a relevant criterion for choosing comparable [R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Assessee Engaged In Offshore Information Technology Enabled Services-Not to be included in list of comparables-Company having different financial year-Results of company for relevant financial year could be carved out-To be included in list of comparables-Working Capital Adjustment-Allowable on actual basis without any restriction.

S. 92C : Transfer pricing-Arm’s length price-Comparables-Certification services-Royalty-Only when combined approach not accepted there could be a separate benchmarking of payment towards royalty-Matter remanded. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software Development Service Provider-Companies having turnover in excess of Rs. 200 Crores not comparable-Companies having multiple segments cannot be compared with captive service providers. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Payment of royalty-Receipt of commission for Marketing Services-Addition was deleted following the order of earlier year. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Purchase of raw material from associate enterprise-Assessee denied opportunity of hearing before Dispute Resolution Panel-Order set aside and remanded. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee to associate enterprise-Transfer Pricing adjustment to be restricted to 0.5% of corporate guarantee.

S. 92C : Transfer pricing-Arm’s length price-Interest-Free Advances-Issue of shares against loan not been made during year-Transfer pricing adjustment in respect of interest-free advances to Associated enterprises proper-Transfer Pricing Officer to ascertain applicable Libor during year and make adjustment. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Transactional net margin method-Comparables-Assessee engaged in business of software development service and Information Technology service-Company with turnover of more that 200 crores-Company having less than 75% revenue from software development services-Company providing high end services-To be excluded-Profit level indicator-Assessee depreciating at a higher rate than comparables-Margin to be adopted after excluding depreciation-Resale Price Method-Rejection of assessee’s application for resale price method-TPO to consider application as per transfer pricing study-Matter Remanded.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Business of Information Technology enabled services-Extraordinary event of amalgamation-Company to be excluded-Company earning income from associated enterprise-more than 25% of its total revenue-To be excluded-Company having very high turnover is to be excluded. [S. 144C(5)]