Tribunal held that the assessee rendering ITES services to AE, a company which was showing fluctuating margins, could not be accepted as comparable. Fee for advisory and other services to AE matter remanded. (AY. 2013-14)
Emerson Climate Technologies (India) (P.) Ltd. v. Dy. CIT (2018) 194 TTJ 41 / 100 taxmann.com 478 (Pune)(Trib.)
S. 92C : Transfer pricing-Arms’ length price-Fluctuation margins- Rendering ITES services to AE, a company which was showing fluctuating margins, could not be accepted as comparable- Fee for advisory and other services to AE matter remanded.