Tribunal held that Losses incurred in only one year hence the Companies can be included. Financial statements of companies from public domain. Matter remanded for verification. Functionally different, equipment different from a component manufacturing company cannot be compared. Working capital adjustment must be given.Matter remanded. Adjustment is restricted to International transaction with Associated enterprise.(AY. 2013-14)
TE Connectivity India P. Ltd. v. Dy. CIT, LTU (2022) 99 ITR 379 (Bang) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Comparables-Loss making companies-Losses incurred in only one year-Companies can be included-Financial statements of companies from public domain-Matter remanded-Functionally different-Equipment Different from a component manufacturing company-Cannot be compared-Working capital adjustment-Additional evidence-Matter remanded-Adjustment is restricted to International transaction with Associated enterprise [S.92CA]