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)]

S. 92C : Transfer pricing-Arm’s length price-Profit margin to be applied only on international transactions. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Assessee in the business of ship chartering services-Rules required Transactional Net Margin Method with respect to net profit margin-Assessee using internal comparables with associated enterprises-Incorrect approach-Revenue authority justified in rejecting methodology. [R. 10B(1)(e)]

S. 92C : Transfer pricing-Arm’s length price-Fee for Corporate guarantee from associated enterprise-Source of TPO for figuring out that assessee issued corporate guarantee not clear-Additions deleted by CIT (A) is justified. [S.92CA]

S. 92C: Transfer pricing-Arm’s length price-Comparable uncontrolled price method-Interest earned on loan to associated enterprise-Justified in deleting addition. [S.92CA]