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| The Tax Publishers2019 TaxPub(DT) 2958 (Bom-HC) INCOME TAX ACT, 1961
Section 92C
Comparison to determine ALP could not be done by comparing prices charged to other AEs, i.e., controlled transactions, TP adjustment of transactions with AEs in USA had to be done/arrived at by making comparisons with uncontrolled parties in USA.
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Transfer pricing - Determination of ALP - Comparison with price charged to other AEs -
TPO determined ALP to sales of vales and kits made to AE based at USA by comparing its margin with other sales by assessee to its other AEs in different parts of the world. Held: Comparison to determine ALP could not be done by comparing prices charged to other AEs, i.e., controlled transactions, TP adjustment of transactions with AEs in USA had to be done/arrived at by making comparisons with uncontrolled parties in USA.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2004-05
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