Tribunal held that Net margin is higher than the margin of the comparables, addition was deleted-It is not obligatory for the assessee to demonstrate as to whether or not the international transaction has resulted into economic benefit. (AY. 2010-11 to 2012-13)
Dow Agrosciences India (P) Ltd. v. ACIT (2021) 214 TTJ 1064 / 126 taxmann.com 240/(2022) 214 DTR 291 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Royalty-Net margin is higher than the margin of the comparables, addition was deleted-It is not obligatory for the assessee to demonstrate as to whether or not the international transaction has resulted into economic benefit. [S. 92BF(ii)]