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Case Law Details

Case Name : PCIT Vs Freescale Semiconductor India Pvt Ltd (Delhi High Court)
Related Assessment Year : 2013-14
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PCIT Vs Freescale Semiconductor India Pvt Ltd (Delhi High Court)

Delhi High Court held that functionally dissimilar entities cannot be included as a comparable entity for benchmarking the Arm’s Length Price (ALP) of the international transactions. Accordingly, appeal of the revenue dismissed.

Facts- The assessee had furnished its transfer pricing study before the Transfer Pricing Officer (TPO) to establish that its international transactions were on ALP. The assessee had adopted Transactional Net Margin Method (TNMM) as the most appropriate method and Oper

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