M/s Panasonic India Pvt. Ltd. Vs. Income Tax Officer (ITAT Delhi)

The advertisement reimbursement would definitely form a part of the operating profits of the assessee and would have to be taken into account for purposes of transfer pricing analysis.

in view of the correct analysis and working as given above on the comparison between the assessee and the com parables and by correcting the two errors committed by the TPO and CIT(A) and confining the financials to one year only and not to multiple years for the trading functioning of assessee, the PLI of the assessee comes to 8.43% and that of

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