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| The Tax Publishers2020 TaxPub(DT) 4712 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Assessee being captive unit of its parent company operated in an environment which was free of risk, and resultantly, its margin of profit for the said reason was on lower side. Therefore, claim of assessee for risk adjustment while benchmarking its international transactions in the backdrop of the financial of comparables companies merited acceptance.
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Transfer pricing - Determination of ALP - Comparables and adjustment - Risk adjustment--Assessee being captive unit of its parent company operated in risk free environment
Assessee having rendered SWD services to its AE abroad, sought for risk adjustment while computing PLI. TPO denied this. Held: Admittedly, assessee being captive unit of its parent company operated in an environment which was free of risk, and resultantly, its margin of profit for the said reason was on lower side. Therefore, claim of assessee for risk adjustment while benchmarking its international transactions in the backdrop of the financial of comparables companies merited acceptance. AO was directed accordingly.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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