Weatherford Drilling And Production Services (India) P. Ltd. v Asst. CIT (2023)106 ITR 46 (SN) / 154 taxmann.com 248 (Ahd) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Sale of goods to associated enterprises-Comparative-Matter remanded to the Assessing Officer .

Tribunal held that the Transfer Pricing Officer had sought to compare the valves which were a consumer product with the industrial product of the tested party, which would not give a true picture of the profits. However, despite these directions of the Tribunal, the directions had not been followed and the same comparable, which was directed to be excluded was again used for conducting the comparability analysis. In view of the above, the matter was to be restored to the Transfer Pricing Officer for carrying out a fresh benchmarking analysis in light of the observations made by the Tribunal.(AY.2009-10, 2010-11)