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]

S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee-Matter remanded [S.92B]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Working capital adjustment-Interest on outstanding receivables. Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Adjustment made in respect of international transaction on purchase of traded goods-Comparable-Adjustment was deleted.

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]