S. 92C : Transfer pricing-Arm’s length price-Transactional net margin method-Comparables-Assessee engaged in business of software development service and Information Technology service-Company with turnover of more that 200 crores-Company having less than 75% revenue from software development services-Company providing high end services-To be excluded-Profit level indicator-Assessee depreciating at a higher rate than comparables-Margin to be adopted after excluding depreciation-Resale Price Method-Rejection of assessee’s application for resale price method-TPO to consider application as per transfer pricing study-Matter Remanded.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Business of Information Technology enabled services-Extraordinary event of amalgamation-Company to be excluded-Company earning income from associated enterprise-more than 25% of its total revenue-To be excluded-Company having very high turnover is to be excluded. [S. 144C(5)]

S. 92C : Transfer pricing-Arm’s length price-Profit margin to be applied only on international transactions. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Assessee in the business of ship chartering services-Rules required Transactional Net Margin Method with respect to net profit margin-Assessee using internal comparables with associated enterprises-Incorrect approach-Revenue authority justified in rejecting methodology. [R. 10B(1)(e)]

S. 92C : Transfer pricing-Arm’s length price-Fee for Corporate guarantee from associated enterprise-Source of TPO for figuring out that assessee issued corporate guarantee not clear-Additions deleted by CIT (A) is justified. [S.92CA]

S. 92C: Transfer pricing-Arm’s length price-Comparable uncontrolled price method-Interest earned on loan to associated enterprise-Justified in deleting addition. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Software development and services and Information Technology–Outsourcing model of business–Company merged with two other companies, growth of revenue increased-Not to included in the list of comparables.

S. 92C : Transfer pricing-Arm’s length price-Manufacture and assembly-Comparable-Company passed turnover filter but fails to pass functional analysis-Department’s appeal to remand the matter not justified and entertained-Addition was deleted [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Aggregation- Aggregation is not a rule of blind application and it is to be applied in certain situations and there has to be a scientific or rational basis for adoption; unless characteristic of ‘closely-linked’ is satisfied, aggregation is not possible-Matter remanded.

S. 92C : Transfer pricing-Arm’s length-Commercial expediency of expenditure-No separate adjustment is required to be made.