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]

S. 92C : Transfer pricing-Arm’s length price-Loans advanced to Associated Enterprises-Rate of interest for benchmarking foreign currency denominated loan-Libor to be taken as the basis-Not Indian prime lending rate-Pledge of shares for benefit of associated enterprise-To be benchmarked Rate at 0.5 Per Cent-Price adjustment scaled down to five Per Cent. of correct value of shares and for actual pledge period. [S.92B]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software development service provider-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Comaparables-Turnover filter-Turnover more than Rs. 200 Crores to be excluded-Cloud services-to be excluded-Receivable-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Comparable–Company having huge turnover and high profit margin and owning intangible intellectual property rights-Companies to be excluded-Company satisfying export turnover-To be included-Business process outsourcing activity”-Companies to be included-Working capital adjustment-Matter remanded. [S.92D R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Matter remanded. [S. 92D]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Companies whose turnover more than Rs. 200 Crores cannot be taken as comparable-Working capital adjustment-Matter remanded. [S.92CA]