The reasons given by the TPO were very general in nature merely referring to the profit margin of eligible units to the non-eligible units and the TPO had not given any analysis to demonstrate how the purchases of any material by the eligible units from the non-eligible units could have yielded extra profits. No downward adjustment of profits of eligible units was called for (AY. 2014-15)
Greenply Industries Ltd. v. ACIT (2022) 219 TTJ 257/220 DTR 18 / 143 taxmann.com 364 (Gauhati) (Trib)
S. 92C : Transfer pricing-Arm’s length price-TPO did not give any analysis to demonstrate how purchase of any material by eligible units from non-eligible units could have yielded extra profits-No downward adjustment of profit of eligible units (S. 80-IA(10)