Tribunal set-aside the order to the file of the AO/TPO for a fresh determination of the ALP of payment of professional fee and directed that the benchmarking would be done by taking the assessee itself as a tested party and Indian comparables and then applying a correct method. (AY. 2010-11)
Dy.CIT v. CarraroIndia Pvt. Ltd. (As a Successor of Turbo Gears India Pvt. Ltd.) (2020) 185 DTR 78 / 203 TTJ 623 (Pune)(Trib.)
S. 92C : transfer pricing–Arm’s length price–Professional fees-TNMM-CUP method–Matter remanded to the TPO.