S. 92C : Transfer pricing-Arm’s length price-Functional similarity-Business of manufacturing and distributing products of consumer electronics and home appliances category-Providing an online marketing platform for sale of electronic products of multiple brands-Designing and manufacturing of only mobile phones-Having brand owning and outsourcing its manufacturing activities to third party contractors could not be accepted as a valid comparable-Would not be accepted as a valid comparable.

S. 92C : Transfer pricing-Arm’s length price-Export of customers electronic data-Comparable-Functionally different-Not acceptable as comparable-Interest receivable-No separate adjustment for interest on receivable was to be made.

S. 92C : Transfer pricing-Arm’s length price-Restricted to international transactions with Associated Enterprises.

S. 92C : Transfer pricing-Arm’s length price-TNM method-Cost plus method-TNM was directed to be applied-Beneficiary of AMP expenses or promotion of brand, said transfer pricing adjustment was to be deleted-Adjustment of royalty-Directed to be deleted.

S. 92C : Transfer pricing-Arm’s length price-Profit Split Method Royalty and AMP expenses-Required to be shown separately-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally similarity-Safe to exclude it from final list of comparables to assessee who had been following fixed price project model-turnover filter of Rs. 1 crore, companies having turnover of more than Rs. 200 crores have to be excluded.

S. 92C : Transfer pricing-Arm’s length price-Foreign exchange fluctuation gain/loss be treated as an operating income / expenses-Comparable-Rejection of comparable was held to be not valid-Failure to provide annual report-Rejection of comparable was held to be valid-Customers whose segmental information was not available. could not be accepted as valid comparable-a comparable company engaged in purchase and sale of products could not be accepted as valid comparable-TP adjustment, if any, has to be restricted to international transactions of assessee with its Associated Enterprises only. [S. 92A]

S. 92C : Transfer pricing-Arm’s length price-Resale method-Trading in India-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Order passed without giving any finding-Matter remanded. [S. 254(1)]

S. 92C : Transfer pricing-Arm’s length price-Interest free loan to Associated enterprises-Libor rate is to be applied-Corporate guarantee-Guarantee commission/fee to be charged at 0.5 per cent. [S. 92B]