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.

S. 92C : Transfer pricing-Arm’s length price-Comparables-Certification services-Royalty-Only when combined approach not accepted there could be a separate benchmarking of payment towards royalty-Matter remanded. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software Development Service Provider-Companies having turnover in excess of Rs. 200 Crores not comparable-Companies having multiple segments cannot be compared with captive service providers. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Payment of royalty-Receipt of commission for Marketing Services-Addition was deleted following the order of earlier year. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Purchase of raw material from associate enterprise-Assessee denied opportunity of hearing before Dispute Resolution Panel-Order set aside and remanded. [S. 92CA]