Held that\u00a0 certain expenses incurred by the assessee, for travelling, etc., on behalf of its associated enterprises, were reimbursed on cost-to-cost basis. In the past the Revenue had accepted that on the reimbursement of expenditure, no markup was required to be charged. However, in the year under consideration, the Revenue had changed its stand. In none of the orders from the assessment years 2002-03 to 2009-10, had the Transfer Pricing Officer held that the pass-through cost or reimbursement incurred by the assessee should have been included in its cost base. The Transfer Pricing Officer\u2018s order showed that he had not disputed any of the comparables selected by the assessee. Therefore, the set of comparables selected by the assessee deserved to be accepted as it had become final for the assessment year. Computation of the margin considering the reimbursement as cost base at 19.45 per cent. was also accepted by the Transfer Pricing Officer. The margin of the comparable companies selected by the assessee was 8.69 per cent. There was no reason to sustain the addition an account of adjustment of markup on pass-through cost claimed by the assessee. Accordingly, the transfer pricing adjustment was\u00a0\u00a0 deleted. (AY.2010-11)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 92C : Transfer pricing-Arm\u2019s length price-Operating costs-Reimbursement of certain costs from Associated Enterprises-No Adjustment of markup on Assessee\u2019s claim of pass-through cost. [S. 92CA] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-36415","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-9tl","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/36415","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=36415"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/36415\/revisions"}],"predecessor-version":[{"id":36416,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/36415\/revisions\/36416"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=36415"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=36415"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=36415"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}