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]

S. 92C : Transfer pricing-Arm’s length price-Provision for bad debts to be treated as non-operating expenditure for purpose of computing profitability under transfer pricing provisions-Companies having bad debt should be considered in final set of comparables-Remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment-Question of adjustment on negative working capital does not arise-Selection of comparables-Companies engaged in diversified activities and earning revenue from various activities and no segmental data available, companies not passing employee cost filter, cannot be taken as comparable-On facts rejection of rental expenses is 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 not sustainable.[S.92CA(3)]

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment permissible for better comparability [S.92CA, R. 10B(1)(e) (iii)]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Turnover more than Rs. 200 Crores to be excluded from list of comparables-Functionally similar companies cannot be excluded from list of comparables–Working capital adjustment-Directed to examine as per OECD guidelines–Interest on delayed realisation of trade receivables-Prime lending rate not to be considered for determining interest rate-Matter remanded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Giant risk taking company engaged in development and sale of software products and owns intangible assets-Company engaged in product development and earning revenue from trading of software licences and subscription-Not to be included in list of comparables. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price–Most Appropriate Method-Cost Plus Method-Direction to benchmark international transactions adopting cost plus method.[S.92CA]