S. 92C : Transfer pricing-Arm’s length price-Abnormal raw material consumption-Directed to pass a speaking order-Comparable-Net margin method-Working capital adjustment-Allowable-Interest on external commercial borrowings-Libor + 150 basis points justified-Interest charged within range in accordance with RBI;s Master circular-Adjustment deleted. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Loans advanced to Associated Enterprises-Rate of interest for benchmarking foreign currency denominated loan-Libor to be taken as the basis-Not Indian prime lending rate-Pledge of shares for benefit of associated enterprise-To be benchmarked Rate at 0.5 Per Cent-Price adjustment scaled down to five Per Cent. of correct value of shares and for actual pledge period. [S.92B]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software development service provider-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Comaparables-Turnover filter-Turnover more than Rs. 200 Crores to be excluded-Cloud services-to be excluded-Receivable-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Comparable–Company having huge turnover and high profit margin and owning intangible intellectual property rights-Companies to be excluded-Company satisfying export turnover-To be included-Business process outsourcing activity”-Companies to be included-Working capital adjustment-Matter remanded. [S.92D R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Matter remanded. [S. 92D]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Companies whose turnover more than Rs. 200 Crores cannot be taken as comparable-Working capital adjustment-Matter remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Operating costs-Reimbursement of certain costs from Associated Enterprises-No Adjustment of markup on Assessee’s claim of pass-through cost. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Functionally dissimilar-Huge turnover and a giant company-Extrodinary events-Excluded from final list of comparable companies-Deferred trade receivables constitute International Transaction-Rate of Libor at six months + 400 basis points adopted by TPO was without any basis-Matter remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Sale of ophthalmic surgical electronic equipment, intraocular lenses, spare parts and pharmaceutical products.-Advertisement, marketing and sales promotion expenses-Bright Line Test-Expenditure incurred cannot be treated as International Transaction-Addition was deleted-Comparable-Functionally different companies cannot be taken as comparables. [S. 92CA]