S. 92C : Transfer pricing-Arm’s length price-Comparable-Negative margin-Comaprable-Segmental details relating to various segments were not available–Sale of software license-Segmental details relating to revenue earned were not discernible-Could not be selected as comparable. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Failure to place verifiable information-Justified in rejecting as tested party-Turnover filter-Difference in turnover is not substantial-Cannot be excluded-Adjustment should be restricted only to international transactions and not entity level transactions. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Guarantee commission fee of 1 percent-Held to be reasonable-Followed order of earlier year-Share capital-Adjustment of interest to be made with other loans giving similar privilege-Business expenditure-TPO only has to ascertain arm’s length price of a transaction and it is not TPO’s job to decide whether a business enterprise should have incurred a particular expense or not. [S. 37(1), 92CA]

S. 92C : Transfer pricing-Arm’s length price-Captive power plants-Eligible business-(State Electricity Board (SEB)-Transaction of transfer of power in Rajasthan from eligible unit to non-eligible unit should be benchmarked at purchase price of power from SEB-Steam cannot be determined at nil. [S. 80IA 92BA]

S. 92C : Transfer pricing-Arm’s length price-Manufacturing of compressors and mining & production tools-Four types of cost-TPO was not justified in considering only two expenses, namely, manufacturing and marketing as contributing to earning of profits. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Engineering design services-Separate segmental accounts-Adjustment made by TPO was deleted. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Technical service fee-Relief granted for AY. 2004-05 was not challenged-Addition was deleted. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Aggregation of transaction-justified in segregating international transaction of professional charges to be processed independent of other international transactions-Allowability of expenditure-Matter remanded. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Interest on receivables-Reduction of credit period to 30 days from 90 days by Dispute Resolution Panel-Service agreement with associated enterprise amended to 90 days-TPO to consider 90 days-Matter Remanded. [S. 92B (1)]

S. 92C : Transfer pricing-Arm’s length price-Corporate Guarantee Computation of commission at 0.5 percent-Justified [S. 92B]