S. 92C : Transfer pricing-Arm’s length price-Bright Line Test (BLT) AMP expenses-TPO was not justified in holding that by incurring AMP expenditures assessee had promoted brand and marketing intangible of its overseas AE and, thus, it had to be treated as international transaction. [S. 92B]

S. 92C : Transfer pricing-Arm’s length price-Guarantee arrangements, arm’s length guarantee commission charge should be restricted at 0.5 per cent of guaranteed amount-Adjustment of purchases-Eligible and non-eligible units-Downward adjustment was held to be not valid [S. 80IA(10), 92CA]

S. 92C : Transfer pricing-Arm’s length price-CUP method-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee-ALP adjustment on account of corporate guarantee restricted to 0.35%. [

S. 92C : Transfer pricing-Arm’s length price-Guarantee commission-Directed to compute TP adjustment at the rate of 0.5 percent.

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%