S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Net Margin Method-Comparable Uncontrolled Price Method-Processing fees-Local guarantees issued based on counter guarantee received from overseas branches-Adjustment was deleted.

S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Net Margin Method-Comparable Uncontrolled Price Method-Processing fees-Local guarantees issued based on counter guarantee received from overseas branches-Adjustment was deleted.

S. 92C : Transfer pricing-Arm’s length price-Net Margin Method-Comparable Uncontrolled Price Methods-Bad debts-Written off-Write off does not affect the Arm’s length price. [S. 36(1)(vii)]

S. 92C : Transfer pricing-Arm’s length price-Profit split method inappropriate-Assessee made no unique intangible contribution-Transactional net margin method appropriate-TPO to recompute arm’s length price. [S.92CA, 144C]

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustment-Information regarding comparable companies not available in public domain-Matter remanded to Assessing Officer/Transfer Pricing Officer to decide issue afresh after affording opportunity of being heard. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Capital Utilization-Functioning at lower capacity than average-Adjustment for underutilization required-Import of raw material-Loss due to foreign exchange rates fluctuation-Foreign exchange rates fluctuation adjustment to be considered-Matter remanded to TPO. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Reconciliation of revenue-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-Turnover more than 200 crores-Assessee company making less than 200 crores in current year-Margin of current year alone to be taken. [S. 92A]

S. 91 : Double taxation relief-Countries which no agreement exists-Foreign tax credit-Delay in filing Form 67-Entitle to claim Foreign tax credit. [S. 139(5), R. 128(9) Form, 67]

S. 90 : Double taxation relief-Not made arrangements for declaration of dividends out of income earned in India-Income was to be charged at a higher rate of tax in India vis-à-vis domestic company and same could not be treated as discrimination on account of fact that assessee belonged to other Contracting State, i.e. Korea-DTAA-India-Korea. [S. 9(1)(i), Art, 25]