Dismissing the appeal of the Revenue the court held that the benchmarking should be done only on the associated enterprises’ transactions and not for the entire turnover. Therefore, the Tribunal was correct in holding that the transfer pricing adjustment should be proportionate to the value of international transaction.
PCIT v. Spicer India Ltd. (No. 1) (2023)458 ITR 40 / (2024) 296 Taxman 431 (Bom.)(HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Benchmarking to be done for only associated enterprises’ transactions and not for entire turnover-Order of Tribunal is affirmed. [S. 260A]