Dismissing the appeal of the revenue the Court held that ; Broad threshold figure of 25 per cent RPT in case of comparables is essential. Brand does play its own role in price or cost determination and, they would not be comparable to each other (AY.2007 -08)
PCIT v. Oracle (OFSS) BPO Services (P.) Ltd. (2018) 253 Taxman 498/ 166 DTR 358 / 303 CTR 284/ (2019) 416 ITR 54 (Delhi) (HC)
S.92C: Transfer pricing- Broad threshold figure of 25 per cent RPT in case of comparables is essential- Brand does play its own role in price or cost determination and, they would not be comparable to each other