S. 92C : Transfer pricing-Arm’s length price-Manufacturing segment-Under-Utilisation of capacity-Working capital adjustment-Foreign Exchange gain erroneously treated as Foreign Exchange Loss and included as part of cost-Payment made for group services-Mistake in treating the foreign exchange gain as foreign exchange loss and including it as part of cost was a computational mistake, required to be corrected in order to arrive at the correct margin-It was also held that the transfer pricing adjustment to the sales made to associated enterprises, under the transactional net margin method was required to be restricted to international transactions only.[S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment-No expenses incurred for Meeting working capital requirement-Question of adjustment on negative working capital does not arise–Selection of comparables-Assessee engaged in provision of software development and related services-Rejection of rental expenses held to be proper. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Royalty-Transactions Valued at Nil ignoring evidence brought on record-Transfer Pricing Adjustment is not sustainable.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Technical Know-how fees-Not adopting one of mandatorily prescribed methods-Deletion of addition is valid.

S. 92C : Transfer pricing-Arm’s length price-Technical Know-how fees-Not adopting one of mandatorily prescribed methods-Deletion of addition is valid.

S. 92C : Transfer pricing-Arm’s length price-Custom duty-Recovering part from customers-Adjustments required to be made. [R. 10B(1)(b)(iv)]

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.