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]

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]