Transfer Pricing – ITAT Explains Law On Adjusting For Differences In Comparables

Demag Cranes & Components (India) Pvt. Limited Vs. DCIT (ITAT Pune)- provisions of 10B(1)(e)(iii) of the Income tax Rules, 1962, which provides for the adjustments in the context of TNMM. From the above, it is explicitly clear that the for the arriving at the arm’s length price (ALP) as per TNMM, the net profit margin arising out of the comparable uncontrolled transactions is adjusted to take into account differences, if any between the (i) international transactions and filtered comparables of uncontrolled transactions or enterprises entering into such transactions, which could mate...