PCIT v. Organon India Pvt Ltd (2023) The Chamber’s Journal – April – P. 133 ( Cal )( HC)

S. 92C : Transfer pricing – Arm’s length price -Outsourcing its manufacturing activity – Advertisement , marketing and promotion expenses – Transfer pricing adjustment is not justified . [ S. 92B ]

Dismissing the appeal of the Revenue the Court held that the Tribunal was justified in deleting the adjustment made by the Transfer Pricing Officer . ( ITAT /16 /2020 dt . 13 -3 2023 )