PCIT v. Schott Glass India (P) Ltd. (2023) 335 CTR 507 (Bom) (HC)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction–PLI vis-a-vis extra-ordinary item-Solar test activity was an extraordinary item and was not part of the regular business of assessee and there was impairment of asset and therefore it had to be excluded for arriving at PLI-No substantial question of law.[S. 260A]

Dismissing the appeal of the Revenue the Court held that the Tribunal was correct in not interfering with the order of the DRP with regard to computation of PLI; DRP has correctly held that the solar test activity was an extraordinary item and was not part of the regular business of assessee and there was impairment of asset and therefore it had to be excluded for arriving at PLI.  No substantial question of law. (AY  2010-11)