Held, dismissing the appeal, the Court that Tribunal was correct in holding that the transfer pricing adjustment under section 92C should be proportionate to the value of international transaction. Provision for warranty-Tribunal deleting disallowance Proper. No substantial question of law.
PCIT v. Mahle Behr India Ltd. (formerly known as Behr India Ltd.) (2025) 482 ITR 1000(Bom)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Tribunal holding transfer pricing to be proportionate to value of international transaction-Business expenditure-Provision for warranty-Tribunal deleting disallowance Proper-No substantial question of law. [S.37(1), 260A]
Leave a Reply