Allowing the appeal the Tribunal held that since TPO did not resort to transfer pricing exercise as per any of methods as prescribed in section 92C(1), transfer pricing adjustment was to be deleted. (AY. 2013-14)
Henkel Chembond Surface Technologies Ltd. v. ACIT (2021) 187 ITD 406 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Management fee-TPO did not resort to transfer pricing exercise adjustment-Addition was to be deleted. [S. 92C(1)]