Tribunal held that the DRP had determined mark up rate at 10 per cent on basis of financial results of assessee-company, but it had not brought on record any external supporting material to substantiate said mark-up rate, determination of rate of markup would require fresh examination. (AY. 2010-11)
Tata Coffee Ltd. v. DCIT (2021) 189 ITD 128 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Reimbursement of expenses-Mark up was directed to be re-examined.