S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Matter remanded. [S. 92D]
Dow Chemical International P. Ltd. v. ITO (2022)100 ITR 82 (Mum)(Trib)S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Matter remanded. [S. 92D]
Dow Chemical International P. Ltd. v. ITO (2022)100 ITR 82 (Mum)(Trib)S. 92C : Transfer pricing-Arm’s length price-Comparables-Companies whose turnover more than Rs. 200 Crores cannot be taken as comparable-Working capital adjustment-Matter remanded. [S.92CA]
Capco Technologies P. Ltd. v. Dy. CIT (2022)100 ITR 280 (Bang)(Trib)S. 92C : Transfer pricing-Arm’s length price-Operating costs-Reimbursement of certain costs from Associated Enterprises-No Adjustment of markup on Assessee’s claim of pass-through cost. [S. 92CA]
Capgemini India Pvt. Ltd. v. Dy. CIT (2022) 99 ITR 506 (Mum)(Trib)S. 92C : Transfer pricing-Arm’s length price-Comparables-Functionally dissimilar-Huge turnover and a giant company-Extrodinary events-Excluded from final list of comparable companies-Deferred trade receivables constitute International Transaction-Rate of Libor at six months + 400 basis points adopted by TPO was without any basis-Matter remanded. [S.92CA]
Altisource Business Solutions Pvt. Ltd. v. ITO (2022) 99 ITR 647 (Bang) (Trib)S. 92C : Transfer pricing-Arm’s length price-Sale of ophthalmic surgical electronic equipment, intraocular lenses, spare parts and pharmaceutical products.-Advertisement, marketing and sales promotion expenses-Bright Line Test-Expenditure incurred cannot be treated as International Transaction-Addition was deleted-Comparable-Functionally different companies cannot be taken as comparables. [S. 92CA]
Alcon Laboratories (India) Pvt. Ltd v. Dy. CIT (2022) 99 ITR 357 (Bang) (Trib)S. 92C : Transfer pricing-Arm’s length price-Comparables-Loss making companies-Losses incurred in only one year-Companies can be included-Financial statements of companies from public domain-Matter remanded-Functionally different-Equipment Different from a component manufacturing company-Cannot be compared-Working capital adjustment-Additional evidence-Matter remanded-Adjustment is restricted to International transaction with Associated enterprise [S.92CA]
TE Connectivity India P. Ltd. v. Dy. CIT, LTU (2022) 99 ITR 379 (Bang) (Trib)S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover more than Rs.200 crores-Excluded-Working capital adjustment. [S. 92CA]
GE Be Pvt. Ltd. v. Dy. CIT (2022)99 ITR 47 (SN)(Bang)(Trib)S. 92C : Transfer pricing-Arm’s length price-Restricted only to the international transactions-VRS expenses-Similar cost incurred by the comparables if any also be given. [S.37(1), 92CA]
Rieter India (P) Ltd. v. Dy. CIT (2022) 215 TTJ 13 (UO) (Pune) Trib)S. 92C : Transfer pricing-Arm’s length price-Providing Crew for Employment on Principal’s Vessels-Agency fee-Expenses incurred reimbursed by associated enterprise-Adjustment was made based on incorrect appreciation of facts-Adjustment was deleted.[S. 144C]
Zodiac Maritime Agencies India Pvt. Ltd. v. NEACE (2022) 98 ITR 48 (SN) (Mum)(Trib)S. 92C : Transfer pricing-Arm’s length price-Most appropriate method-Resale of online advertisement space-Resale Price Method most appropriate method.
Dy. CIT v. Komli Wedia India P. Ltd. (2022) 98 ITR 5(SN)(Mum) (Trib)