G. S. Caltex India P. Ltd. v. DCIT (2018) 65 ITR 36 (SN) / 171 DTR 345 196 TTJ 612 / 96 taxmann.com 614(Mum) (Trib)

S. 92C : Transfer pricing – Arm’s length price – Procuring and importing lubricants – TNM is appropriate method – Assessee to be given adjustments for extraordinary costs incurred in first year of operations-AO is directed to re compute the arm’s length price.

Tribunal held that ,for computing arm’s length price , in respect of importing lubricants , TNM  is appropriate method .Assessee to be given adjustments for extraordinary costs incurred in first year of operations-AO is directed to re compute the  arm’s length price.   ( AY.2011-12)