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%

S. 92C : Transfer pricing-Arm’s length price-Transfer pricing adjustment should be restricted only to international transactions and not at entity level [Rule. 10AB]