S. 92C : Transfer pricing-Arm’s length price-Comparables, functional similarity-Least complex entity to a transaction should be adopted as a tested party-Composite set of books of account-Aggregation of transactions-Transfer pricing adjustment should be restricted only to international transactions. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Methods for determination of-Resale price method-International transaction is not that of purchase by an Indian entity, then RPM cannot be applied-Brand building expenses-Employees cost and operating and administrative expenses incurred for year in question and claimed as deduction in entirety in year alone could not be treated as Brand building expenses. [R. 10B(1)(b)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally not comparable-Excluded from the list of comparbles. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Transfer Pricing Officer was directed to compute profit level indicator of assessee at. 11.35 Per Cent-Selection of comparable-Functionally comparable to be included as comaparble. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Advertisement, marketing and promotion expenditure-estimation at ad hoc figure of 1 per cent. of gross sales-Adjustment is not proper. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Functionally different-To be excluded-Tolerance range Of ±5 Per Cent. to be considered-Transaction of overdue receivables covered under capital financing is to be benchmarked separately irrespective of whether interest charged by assessee from non-associated enterprises-Rate of libor +3 Per Cent. for delayed remittances beyond allowable credit period. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Purchase of raw materials-Method accepted in earlier years-Order of CIT(A) is affirmed. [S. 145]

S. 92C : Transfer pricing-Arm’s length price-Medical Transcription Services and Information Technology and Information Technology enabled Services-Receivable outstanding-Addition was deleted.

S. 92C : Transfer pricing-Arm’s length price-Abnormal raw material consumption-Directed to pass a speaking order-Comparable-Net margin method-Working capital adjustment-Allowable-Interest on external commercial borrowings-Libor + 150 basis points justified-Interest charged within range in accordance with RBI;s Master circular-Adjustment deleted. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Loans advanced to Associated Enterprises-Rate of interest for benchmarking foreign currency denominated loan-Libor to be taken as the basis-Not Indian prime lending rate-Pledge of shares for benefit of associated enterprise-To be benchmarked Rate at 0.5 Per Cent-Price adjustment scaled down to five Per Cent. of correct value of shares and for actual pledge period. [S.92B]