Dismissing the appeal of the revenue the Court held that ; a company engaged in business of clinical trial services is comparable to a company providing contract manufacture, contract research and development of drugs to its Associated Enterprises and also as both comparables as well as assessee are situated in India, no adjustment of ALP on account of locational advantage is called for. ( AY.2009 -10)
PCIT v. Watson Pharma (P.) Ltd. (2018) 257 Taxman 65 (Bom) (HC)
S. 92C : Transfer pricing – Arm’s length price – A company in business of clinical trial services is comparable to a company providing contract manufacture, contract research and development of drugs to its Associated Enterprises- Both comparables as well as assessee are situated in India, no adjustment of ALP on account of locational advantage is called for.