The Tribunal held that liability and doubtful debts written back fall within the ambit of section 28 to 43 and therefore, formed part of operating income. Similarly, it was held that design income and services income are directly linked to the core activities of the assessee and therefore, would form part of operating profits. (AY. 2002-03 2004-05)
Dy. CIT v. Tetra Pak India (P) Ltd. (2018) 191 TTJ 48 (UO)( (Pune) Trib.)
S. 92C : Transfer pricing – Arms’ length price – operating profit – liabilities and doubtful debt written back as well as design income and services income form part of operating profit for computing operation profit while calculating OP/OC ratio.