S. 92C : Transfer Pricing-Arm’s Length Price-Manufacturing and marketing-Transactional Net Margin Method most appropriate-Transfer Pricing Officer’s Reasoning of constructing a hypothetical comparable uncontrolled price based on study of third party scenario is not envisaged [S.92CA]

S. 92C : Transfer Pricing-Arm’s Length Price-Comparables-Government of India Company not Comparable with Assessee-Excluded from List of Comparables. [S.92CA]

S. 92C: Transfer pricing-Arm’s length price-Software development services-Working capital adjustment on account of outstanding receivables-Matter remanded. [S.92CA]

S. 92C: Transfer pricing-Arm’s length price-Comparables-Companies with turnover in excess of Rs. 200 Crores-Not comparable.

S. 92C : Transfer pricing-Arm’s length price-Net margin method-Support services to its associated enterprises-Transfer Pricing Officer discarding transactional net margin method adopted by assessee and accepted by Department for several years without assigning any specific reason-Held to be not proper. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Fees for managerial services-No evidence of nature of services rendered-Transfer Pricing adjustment required for consideration paid for services. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Change in method of revenue recognition deferring recognition of revenue-Assessing Officer to give consequential relief in year in which revenue deferred was offered to tax. [S. 145]

S. 92C: Transfer pricing-Arm’s length price-Related party transactions-Threshold limit for applying related party transaction filter should Be 15 Per Cent. or 25 Per Cent. depending upon the availability of comparable companies.

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.