Tribunal held that Volume difference in transaction values, funding issues, environmental issues, geographical location of clients and alleged differences in FAR without specifying same were held not grounds to reject CPM method and adopt TNMM method in oil and gas sector. Tribunal also held that period of 90 days for pronouncement of orders after date of hearing is to be computed by excluding period during which nationwide COVID 19 pandemic lockdown was in force.
Mott MacDonald (P.) Ltd. v. CIT (2020) 184 ITD 656 / 190 DTR 21 / 206 TTJ 30 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Volume difference in transaction values, funding issues, environmental issues, geographical location of clients and alleged differences in FAR without specifying same were held not grounds to reject CPM method and adopt TNMM method in oil and gas sector-Appellate Tribunal-Period of 90 days for pronouncement of orders after date of hearing is to be computed by excluding period during which nationwide COVID 19 pandemic lockdown was in force. [S. 255, ITAT R. 34]