S. 92C : Transfer pricing-Arm’s length price-Guarantee commission fee of 1 percent-Held to be reasonable-Followed order of earlier year-Share capital-Adjustment of interest to be made with other loans giving similar privilege-Business expenditure-TPO only has to ascertain arm’s length price of a transaction and it is not TPO’s job to decide whether a business enterprise should have incurred a particular expense or not. [S. 37(1), 92CA]

S. 92C : Transfer pricing-Arm’s length price-Captive power plants-Eligible business-(State Electricity Board (SEB)-Transaction of transfer of power in Rajasthan from eligible unit to non-eligible unit should be benchmarked at purchase price of power from SEB-Steam cannot be determined at nil. [S. 80IA 92BA]

S. 92C : Transfer pricing-Arm’s length price-Manufacturing of compressors and mining & production tools-Four types of cost-TPO was not justified in considering only two expenses, namely, manufacturing and marketing as contributing to earning of profits. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Engineering design services-Separate segmental accounts-Adjustment made by TPO was deleted. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Technical service fee-Relief granted for AY. 2004-05 was not challenged-Addition was deleted. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Aggregation of transaction-justified in segregating international transaction of professional charges to be processed independent of other international transactions-Allowability of expenditure-Matter remanded. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Interest on receivables-Reduction of credit period to 30 days from 90 days by Dispute Resolution Panel-Service agreement with associated enterprise amended to 90 days-TPO to consider 90 days-Matter Remanded. [S. 92B (1)]

S. 92C : Transfer pricing-Arm’s length price-Corporate Guarantee Computation of commission at 0.5 percent-Justified [S. 92B]

S. 92C : Transfer pricing-Arm’s length price-Guarantee commission-Yield spread approach-Adjustments made by the TPO was deleted.[S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-AMP expenses-Adjustments-Not justified-Purchase-Imports-Gross margins of assessee were much more than gross margins of comparable companies chosen by TPO, no adjustment to ALP was to be made in respect of import of finished goods. [S. 92CA]