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]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Loss making companies-Losses incurred in only one year-Companies can be included-Financial statements of companies from public domain-Matter remanded-Functionally different-Equipment Different from a component manufacturing company-Cannot be compared-Working capital adjustment-Additional evidence-Matter remanded-Adjustment is restricted to International transaction with Associated enterprise [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover more than Rs.200 crores-Excluded-Working capital adjustment. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Restricted only to the international transactions-VRS expenses-Similar cost incurred by the comparables if any also be given. [S.37(1), 92CA]

S. 92C : Transfer pricing-Arm’s length price-Providing Crew for Employment on Principal’s Vessels-Agency fee-Expenses incurred reimbursed by associated enterprise-Adjustment was made based on incorrect appreciation of facts-Adjustment was deleted.[S. 144C]

S. 92C : Transfer pricing-Arm’s length price-Most appropriate method-Resale of online advertisement space-Resale Price Method most appropriate method.

S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Net Margin Method-Comparable Uncontrolled Price Method-Processing fees-Local guarantees issued based on counter guarantee received from overseas branches-Adjustment was deleted.

S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Net Margin Method-Comparable Uncontrolled Price Method-Processing fees-Local guarantees issued based on counter guarantee received from overseas branches-Adjustment was deleted.

S. 92C : Transfer pricing-Arm’s length price-Net Margin Method-Comparable Uncontrolled Price Methods-Bad debts-Written off-Write off does not affect the Arm’s length price. [S. 36(1)(vii)]

S. 92C : Transfer pricing-Arm’s length price-Profit split method inappropriate-Assessee made no unique intangible contribution-Transactional net margin method appropriate-TPO to recompute arm’s length price. [S.92CA, 144C]