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No ALP addition towards excessive payment for purchase of machinery if its price wasn't disputed by custom authority

July 19, 2019[2019] 106 taxmann.com 403 (Delhi - Trib.)

TRANSFER PRICING: Where TPO made addition to assessee's ALP in respect of excessive price paid to AE for purchase of Machinery, in view of fact that custom authorities had not disputed declared import price of machine and it was an acceptable method of valuation, impugned addition was to be deleted

TRANSFER PRICING: Where assessee benchmarked international transaction of sale of drugs to AE by adopting TNMM whereas TPO on basis of CUP method made certain addition to assessee's ALP, in view of fact that a mere price comparison of uncontrolled transaction of assessee with another uncontrolled transaction taken from database was a gross error as far as application of CUP method was concerned, impugned addition made by TPO deserved to be deleted

TRANSFER PRICING: Where TPO made addition to assessee's ALP in respect of MCS extract purchased from AE, in view of fact that TPO had not provided any material on basis of which price of MCS extract was to be supported whereas assessee had justifed ALP by usage of TNMM method, impugned addition made by him was to be set aside

TRANSFER PRICING: Where Commissioner (Appeals) confirmed addition made to assessee's ALP by taking a view that interest rate on loan given to AE was to be charged at LIBOR plus 1.5 per cent, in view of fact that DRP for immediately preceding assessment year 2006-07 had held that foreign loan given to UK subsidiary was to be benchmarked at LIBOR plus 300 bps, impugned addition was to be set aside and, matter was to be remanded back for disposal afresh in light of aforesaid direction of DRP

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