Dismissing the appeal of the revenue High Court held that Tribunal is right in applying first and second proviso of Section 92C of the Act and allowing +/-5% range in the case where there is only one reference rate of RBI as a benchmarking rate for determining Arms’ Length Price. (AY. 2010-11)
PCIT v. UAE Exchange & Financial Service Ltd. (2020) 117 taxmann.com 105 (Karn.)(HC) Editorial : SLP of revenue is dismissed as withdrawn due to low tax effect PCIT v. UAE Exchange Technology (P) Ltd (2020) 272 Taxman 19 (SC)
S. 92C : Transfer pricing-Arm’s length price-Safe Harbour rules-RBI rate to be a bench mark-Second proviso to section 92C(2) which allows +/-5 per cent range to could be applied even in a case where transactions involved were an account of trading in foreign exchange.