Income Tax Appellate Tribunal – Pune
A Raymond Fastenes India … vs Deputy Commissioner Of … on 1 November, 2021 IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCH, „C‟ PUNE – VIRTUAL COURT
BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND
SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER
आयकर अपीऱ सं. / ITA No.29/PUN/2019
निर्धारण वषा / Assessment Year : 2014-15
A Raymond Fasteners India Pvt. Ltd., Vs. DCIT, Circle-8,
G.No.259, 276/8B, Pune
Nighoje, Taluka Khed,
Pune 410 501
PAN : AAGCA7184G
Appellant Respondent
Assessee by Shri M.P. Lohia
Revenue by Ms. Divya Bajpai
Date of hearing 29-10-2021
Date of pronouncement 01-11-2021
आदे श / ORDER
PER R.S. SYAL, VP :
This appeal by the assessee emanates from the final
assessment order dated 24-10-2018 passed by the Assessing Officer
(AO) u/s.143(3) r.w.s.144C(13) of the Income-tax Act, 1961
(hereinafter also called „the Act‟) in relation to the assessment year
2014-15.
2. The assessee is aggrieved by the transfer pricing addition of
Rs.8,96,78,966/- made by the AO in the impugned order.
Succinctly, the facts of the case are that the assessee filed its return
declaring total loss of Rs.19.51 crore. Certain international
transactions were declared in Form No.3CEB. The AO made a
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reference to the Transfer Pricing Officer (TPO) for determining the
arm‟s length price (ALP) of the international transactions.
Instantly, we are concerned with two international transactions,
namely, (1) Purchase of material with transacted value of
Rs.20,86,13,739/-; and (2) Sale of finished goods amounting to
Rs.79,28,917/-. The assessee benchmarked these two transactions
by applying the Transactional Net Margin Method (TNMM). The
assessee selected two Associated Enterprises (AEs) as tested parties
for the international transaction of `Purchase of material‟, and for
the `Sale of finished goods‟, it chose itself as a tested party. In fact,
the assessee made total purchase of material worth Rs.24.01 crore
from its 13 AEs including Rs.3.14 crore capitalized as `Purchase of
Mould‟. However, the benchmarking analysis was done for the
international transaction of Purchase of raw material worth Rs.20.86
crore by considering only two AEs, namely, (i) A Raymond
(France); and (ii) A Raymond (Germany) as tested parties. Eight
comparable companies were chosen with average Operating Profit
(OP)/Operating Cost (OC) determined at 10.28% as against the
AEs‟ mark up of 10% to show that the transaction was at ALP. The
TPO, in principle, concurred with the assessee‟s submission that
there was no restriction on considering the Foreign/AE as tested
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party. He, however, held that Foreign/AE could be considered as
tested party only subject to certain conditions. Considering the
relevant United Nations Transfer Pricing Manual, OECD Transfer
Pricing guidelines and US TP Regulations, the TPO came to hold
that the Foreign/AEs chosen by the assessee did not satisfy the
requisite criteria. He, therefore, rejected the selection of the two
AEs as tested parties and proceeded with the ALP determination by
taking the assessee as a tested party. He picked up four
comparables, as were chosen by the assessee for the international
transaction of `Sale of Finished goods‟, and determined the ALP of
the aggregate transactions of Purchase of raw material and Sale of
finished goods in a combined basis under the TNMM. The
assessee‟s contention of taking gross margins was rejected. The
arithmetic mean of the OP/OR of the comparables was computed at
1.96% which was compared with the assessee‟s OP/OR at (-)
16.56%. This resulted into recommending a transfer pricing
adjustment of Rs.10,04,36,123/-. The AO notified the draft order
accordingly and reduced the amount of loss to be carried forward at
Rs.9.47 crore. The assessee unsuccessfully assailed the matter
before the Dispute Resolution Panel (DRP), which has brought it
before the Tribunal.
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3. We have heard both the sides through Virtual Court and gone
through the relevant material on record. The following issues arise
in this appeal:-
I. Whether TPO rightly rejected foreign/AEs as tested parties?
II. `Any other method‟ for ALP determination
III. Comparables
IV. TP adjustment on proportionate basis
We will espouse these issues one by one for consideration and
decision.
I. WHETHER TPO RIGHTLY REJECTED FOREIGN/AE AS
TESTED PARTY?
4.1. The first issue raised in this appeal is against the adoption of
the assessee as tested party as against the Foreign/Associated
Enterprise (AE) chosen by it. The assessee benchmarked the
international transaction of Purchase of raw material under the
TNMM as the most appropriate method by taking two AEs as tested
parties. Purchase of raw material was made from 13 AEs, but the
assessee selected only two AEs as tested parties. The TPO did not
dispute that the Foreign/AE could not be considered as tested party,
which view rightly accords with the judgment delivered by the
Hon‟ble Madras High Court in the case of Virtusa Consulting
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Services Private Ltd. Vs. DCIT (124 taxmann.com 309) accepting
the assessee‟s contention that a foreign/AE can also be taken as a
tested party provided it is least complex party to the controlled
transaction and facilitates the ALP determination in a proper
manner. In the ultimate analysis, the Hon‟ble High Court sent the
matter back to the TPO by observing that: `The issue regarding the
assessee‟s plea to consider foreign AE as tested party to determine
the Arm‟s Length nature of the underlying international transactions
stands remanded to the Transfer Pricing officer for a fresh decision
on merits and in accordance with law …‟. The TPO in the instant
case did accept the assessee‟s contention that Foreign/AE can be
taken as a tested party. He, however, went ahead with the exercise
of finding out if the Foreign/AE satisfied the relevant criteria to be
adopted as a tested party. After examining the relevant facts, he
came to hold that the Foreign/AE did not qualify as a tested party.
4.2. In this regard, it is relevant to note the United Nations
Practical Manual on Transfer Pricing (2017). Para B.2.3.3., with the
heading `Selection of the tested party‟, runs as under :
`The tested party normally should be the less complex party to
the controlled transaction and should be the party in respect of
which the most reliable data for comparability is available. It
may be the local or the foreign party. If a taxpayer wishes to
select the foreign associated enterprise as the tested party, it
must ensure that the necessary relevant information about it
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and sufficient data on comparables is furnished to the tax
administration and vice versa in order for the latter to be able
to verify the selection and application of the transfer pricing
method.‟
4.3. From the above U.N. Transfer Pricing Manual, it is clear
that a Foreign/AE can also be taken as tested party provided the
assessee furnishes to the TPO the necessary relevant information
about it and also comparables. This information is crucial for
enabling the TPO to verify the correctness of the ALP determination
done by the assessee. In other words, if the desired information
about the foreign/AE or comparables is not furnished, then the TPO
gets handicapped to benchmark the international transaction,
thereby rendering the selection of foreign/AE meaningless.
4.4. Para 3.18 of the OECD TP Guidelines, 2010 states that „As a
general rule, the tested party is the one to which a transfer pricing
method can be applied in the most reliable manner and for which
the most reliable comparables can be found, i.e. it will most often be
the one that has the less complex functional analysis.‟
4.5. Further, the US Transfer Pricing Regulations discusses the
concept of tested party at § 1.482-5(b) which is reproduced as
under:
“The tested party will be the participant in the controlled
transaction whose operating profit attributable to the
controlled transactions can be verified using the most reliable
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data and requiring the fewest and most reliable adjustments,
and for which reliable data regarding uncontrolled
comparables can be located. Consequently, in most cases the
tested party will be the least complex of the controlled
taxpayers and will not own valuable intangible property or
unique assets that distinguish it from potential uncontrolled
comparables.”
4.6. A bird‟s eye view of the above transfer pricing guidelines
clearly transpires that a tested party is normally the one which is
least complex or performs simpler functions and assumes minimum
risks without owning any valuable intangibles or unique assets; and
for which reliable and verifiable information of self and
comparables is available for perusal and analysis by the Revenue
authorities. The idea is that the relevant information about tested
party – be it the assessee itself or the foreign/AE – should be
available and the same should be made available to the Department
for making the transfer pricing assessment. The thrust is on the
relative easiness of the computation of the ALP, which pre-supposes
its accuracy. If accuracy itself is compromised in the process, then
easiness of the computation is of no avail.
4.7. The assessee harped on the contention before the authorities
below that the two Foreign/AEs were least complex entities and
hence were chosen as tested parties. It is pertinent to note that the
two Foreign/AEs are in manufacturing of raw material/moulds. As
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against that, the assessee has simply purchased such raw material,
for which the ALP determination is warranted. It goes without
saying that manufacturing a product cannot be considered as least
complex vis-à-vis the per se purchase of such goods. The TPO has
noted in his order that the assessee in its transfer pricing study
report indicated that it is French AE: “is the operating entity for the
French market that performs production and distribution activities.
. …. It generates the turnover of approximately EURO 122 million.
The entity is manufacturing, developing and selling fasteners and
quick connectors and employed 683 employees”. Insofar as the
German entity is concerned, the assessee in its transfer pricing study
report mentioned that it: “operates in the metal working and the
plastic processing industry. The Germany subsidiary has a leading
market position in the engineered fastener market by developing
sophisticated products from the first draft to the finished
components for its customers. It has a broad product range from
plastic and metal fasteners to quick connectors and screen washer
nozzles up to cable channels and air deflectors. The entity employs
1610 employees”. As against the above two AEs, the assessee, as
per its own version in transfer pricing study report, as captured in
the TPO‟s order, was set up `in 2008 to address the fast growing
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Indian Automotive market and started to produce in 2009. The
entity employs 113 persons.‟ On a ex facie comparative analysis of
the profile of the two Foreign/AEs vis-à-vis the assessee, it is
pellucid that it is the assessee itself which is least complex rather
than the other two Foreign/AEs.
4.8. Be that as it may, it is significant to mention that the assessee
purchased raw material from thirteen AEs but carried out the entire
benchmarking analysis only with respect to two AEs situated in
Germany and France. There is no whisper about the remaining
eleven entities in the ALP determination and the transactions with
them have also been benchmarked by considering the other two AEs
as tested parties, which have actually no relation whatsoever with
these transactions. Thus benchmarking of transactions with such
eleven Foreign/AEs has proceeded with without taking the assessee
itself or the concerned AE as tested party, which exercise does not
commend of the proper ALP determination.
4.9. An essential ingredient for the adoption of a tested party is
that the reliable and verifiable information about it and the
comparables should be available which should be furnished. Insofar
as the two foreign/AEs are concerned, the TPO has recorded in his
order that the assessee furnished only their financials and not the
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complete Annual reports. Even the financials were incomplete
which were in the form of extracts only. Further, the assessee
claimed that AEs charged 10% markup on operating cost. It is by
reason of this 10% markup that the assessee claimed the margin of
comparables at 10.28%, bringing the transactions within the arm‟s
length range. On a perusal of the TPO‟s order, which has not been
controverted on behalf of the assessee, it clearly transpires that the
assessee was called upon to furnish the details of operating costs of
the foreign/AEs on which the alleged 10% mark-up was added. The
assessee `expressed inability to submit the actual calculation of
costs for AEs’. The assessee even failed to furnish any cost
certificate and documents or working sheets which could
demonstrate the operating costs incurred by the AEs for enabling
the TPO to proceed to the next step of applying 10% markup
thereon. Thus it is established that the claim of 10% mark-up is in
vacuum as even the figures of operating costs of the AEs were not
substantiated in any manner.
4.10. Now we turn to the other aspect, being, the availability and
correctness of information concerning the comparables. Here again,
only the extracts of financial statements from AMADE US database
of such comparable companies were furnished. In the absence of
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the corresponding Annual reports, the TPO found himself unable to
find out if such companies were really qualifying. It is with the help
of the Annual reports that the TPO could find out the precise
functionality of the companies; whether the transactions of the
concerned entities were controlled or uncontrolled?; whether the
RPT and other filters were satisfied?; and whether there were any
extraordinary financial events?; so on and so forth. Unless Annual
report of a company is furnished, a logical decision on its inclusion
in the list of comparables cannot be made. What to talk of others,
even the fundamental requirement of functional comparability of the
company with that of the tested party is not possible. Thus, it is
evident that the assessee failed to furnish not only the reliable and
demonstrable information of the Foreign/AEs but also those of the
comparables chosen.
4.11. The above discussion boils down that neither the foreign/AEs
are least complex nor could the assessee place before the TPO
relevant and verifiable information of the foreign/AEs and
comparables for enabling him to determine the ALP of the
transaction. There is no improvement in the situation before the
Tribunal as well. In fact, the ld. AR candidly admitted that he had
nothing to add further on this score and the ground was taken just to
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keep the issue alive. We, therefore, countenance the view taken by
the TPO in this regard and hold that he was fully justified in
rejecting the Foreign/AE as tested party and adopting the assessee
itself as a tested party.
II. `ANY OTHER METHOD‟ FOR ALP DETERMINATION
5.1. The next issue taken up on behalf of the assessee is that the
TPO erred in rejecting the adoption of gross margins of the tested
party and comparables for benchmarking. The ld. AR submitted
that when the TPO rejected the selection of Foreign/AEs as tested
parties and proceeded with the ALP determination under the
TNMM, a request was made to him vide letter dated 12-10-2017 for
adopting the gross margins as PLI for both the assessee as a tested
party as well as the comparables. The TPO rejected such contention
vide para 9.2 of his order by holding that the assessee was
requesting to use Cost Plus method as most appropriate method in
the guise of adoption of gross margins as PLI, which was not
acceptable. He further noted that in the transfer pricing study report
at page 35, the assessee had itself rejected Cost Plus method. He
still further observed that in the calculation furnished by the
assessee taking gross margin as the PLI, there was no uniformity in
the type of costs included because in some cases freight was
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included while in others it was excluded. The DRP also did not
allow any succour to the assessee.
5.2. We have heard both the sides and gone through the relevant
material on record. The TPO accepted the TNMM as the most
appropriate method, which was applied by the assessee also, but
changed the tested party from Foreign/AEs to the assessee itself.
He adopted four comparables as were given by the assessee for the
second international transaction of `Sale of finished goods‟ and
determined the ALP by taking the assessee as the tested party. Now
the question is whether the authorities were justified in rejecting the
assessee‟s request for adoption of gross margin ratio for
benchmarking.
5.3. It is seen that the assessee took up the contention before the
TPO that the gross margins should be considered as PLI. By
making such a request, the assessee indirectly requested for
adoption of “any other method” as the TNMM admits of taking
operating profit margin in the formula for the ALP determination.
At this juncture, it is relevant to note that rule 10AB of the Income-
tax Rules, 1962 refers to “any other method”, which has been
inserted by the IT (Sixth Amdt. Rules, 2012 w.e.f. 1.4.2012, which
reads as under: –
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`For the purposes of clause (f) of sub-section (1) of section
92C, the other method for determination of the arms‟ length
price in relation to an international transaction or a specified
domestic transaction shall be any method which takes into
account the price which has been charged or paid, or would
have been charged or paid, for the same or similar
uncontrolled transaction, with or between non-associated
enterprises, under similar circumstances, considering all the
relevant facts.‟
5.4. Instantly we are concerned with the A.Y. 2014-15. As such,
there is no legal embargo on adoption of this method. In support of
the gross margins, the assessee furnished a detailed working, a copy
of which has been placed at page 426 onwards of the paper book.
In this working, the assessee calculated its gross margin and that of
the four comparables by considering cost of goods sold, that is, the
raw material cost and other direct costs. The contention now before
the Tribunal is that the gross margins should be computed with
reference to purchase cost of raw material only to the exclusion of
other direct costs vis-a-vis the sale price of finished goods. A slight
modification has been made by the assessee before the Tribunal
urging that gross margins should be considered with reference to
purchase cost of raw material only.
5.5. Rule 10AB permits taking recourse to any method which
takes into account, inter alia, the price paid in an international
transaction `considering all the relevant facts‟. We need to delve
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into the relevant facts in the instant case. It is noticeable from the
submissions made before the TPO that the assessee utilized only
11% of its capacity in Injection press moulding unit and 9% in
Quick connector assembly unit. Consequence of this gross
underutilization of capacity is that the fixed costs of production
could not be properly recovered. Any two companies can be
considered as comparable if they are not only functionally similar
but also pass other tests of comparability including the capacity
utilization. If a company purchases raw material at ALP but
because of its working at a low capacity, the other direct costs are
not fully recovered leading to low gross margin, can it be said that
the purchase of raw material was not at ALP? The way forward is to
allow capacity utilization adjustment in the profit margin of the
comparables under the TNMM by considering the difference in the
extent of capacity utilizations. That is the precise reason for
allowing capacity utilization adjustment. However, to carry out
capacity utilization adjustment, necessary data of the capacity
utilization by the comparables must be available, without which no
such adjustment can be granted. But the mere fact that the capacity
utilization adjustment cannot be granted under the TNMM for lack
of necessary data of comparables, a transaction of purchase of raw
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material, otherwise at ALP, does not cease to be so. In such a
scenario, the assessee can validly adopt “any other method” by
considering the purchase price of raw material alone de hors other
direct expenses vis-à-vis the sale price of finished goods for
computing the resultant gross profit margin of self and the
comparables for making effective comparison. In the given facts
when admittedly the capacity utilization figures of the comparables
are not available and any other method as per rule 10AB is in
vogue, there can be no difficulty in countenancing the assessee‟s
contention of the ALP determination with the gross margin only qua
the raw material cost to the exclusion of other direct expenses.
5.6. The ld. AR furnished calculation of gross profit margins by
taking only the figures of raw material purchases vis-a-vis the sale
price of self and four comparables chosen by the TPO. Since such
figures have not been examined by the authorities below, we cannot
straight away take cognizance of the same. We, therefore, set aside
the impugned order and remit the matter to the file of AO/TPO for
re-determining the ALP under “any other method” as per Rule
10AB by considering purchase price of raw material vis-a-vis sale
price of the finished goods of the assessee as well as the
comparables.
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III. COMPARABLES
6.1. The next issue raised by the ld. AR is against the inclusion of
ITW India Limited in the list of comparables by the TPO. We have
noted above that the assessee selected four companies as
comparable for the transaction of `Sale of finished goods‟. The
TPO aggregated this transaction with the transaction of Purchase of
raw material and adopted the same companies as comparable for
benchmarking. The ld. AR submitted that the TPO erred in
including ITW India Limited in the list of comparables.
6.2. Having heard the rival submissions and gone through the
relevant material on record, it is seen that the assessee suo motu
selected ITW India Limited as a comparable in its transfer pricing
study report and now it is seeking its exclusion. The same way in
which TPO is entitled to abort a company taken by the assessee as
comparable, if it is really not so, there is no impediment in an
assessee claiming exclusion of a company wrongly inducted by it in
the list of comparables. A party cannot be debarred in law seeking
withdrawal of a company which was included on account of a
mistaken notion. We, therefore, reject the preliminary contention
of the ld. DR on this score.
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6.3. The ld. AR cited high turnover of ITW India Limited as a
raison d`etre for its exclusion. For this proposition, he relied on the
judgment of Hon‟ble Bombay High Court in the case of CIT Vs.
Pentair Water India Pvt. Ltd. (2016) 381 ITR 216 (Bom). The ld.
AR relied on a remand report of the TPO, copy placed at page 1460
onwards of the paper book, to argue that the TPO himself adopted
filter of 10 times turnover.
6.4. The Hon‟ble Bombay High Court in the above case approved
exclusion of three companies from the list of comparables by
noticing that their turnover was more than 23 times, 65 times and 85
times of the assessee therein. The Hon‟ble Punjab & Haryana High
Court in Pr. CIT and another Vs. Equant Solutions India Pvt. Ltd.
and Ors. (2020) 421 ITR 655 (P&H) also excluded a company
whose turnover was 24 times. To bolster his point of view, the ld.
AR contended that turnover of ITW India Limited for the year under
consideration was Rs.1033.44 crore as against the assessee‟s
turnover of Rs.54.23 crore. However, on a perusal of the figure of
turnover of ITW India Ltd. from the Statement of profit and loss
account, a copy placed at page 1438 of the assessee‟s paper book, it
can be seen that such turnover includes not only revenue from sale
of products but also sale of services and other operating revenues.
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We are concerned only with the assessee‟s turnover from sale of
products. The equivalent of ITW India Limited is the revenue from
sale of products at Rs.915.72 crore (Rs.992.08 crore minus Excise
Duty of Rs.76.36 crore). Thus, it can be seen that the turnover of
ITW India Limited is only 16.88 times of the assessee, which is far
below the exclusion approved by the Hon‟ble Bombay High Court
at minimum of 23 times. At this stage, it is relevant to mention that
the assessee chose another company, namely, Lifelong India
Limited and included it in the list of comparables. Turnover of
Lifelong India is Rs.532.94 crore, which is about 10 times that of
the assessee.
6.5. Insofar as the reliance of the ld. AR on the remand report of
the TPO applying 10 times turnover filter is concerned, we find that
such a remand report pertains to the proceedings for the A.Y. 2012-
13. In fact, no remand proceedings took place for the A.Y. 2014-15
under consideration. It goes without saying that facts and
circumstances change every year. What is relevant for one year need
not necessarily be relevant for all the years to come. The ALP for
each year has to be determined independently in the hue of the facts
and circumstances relevant for such year only. The assessee‟s
Transfer pricing study report indicates that it applied turnover filter
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with lower limit only without any upper limit. In fact, it is the
assessee who selected ITW India Ltd. by applying the requisite
filters including that of the turnover. The TPO neither disturbed the
turnover filter nor the inclusion of the company. In view of the fact
that ITW India Ltd. satisfies the turnover filter as applied by the
assessee itself and the difference in the turnover of the assessee and
ITW India Limited is not as substantial as was considered germane
for exclusion by the Hon‟ble jurisdictional High Court in Pentair
Water India Pvt. Ltd. (supra) and the further fact that the assessee
itself included Lifelong India as a comparable with 10 times
turnover, we hold that ITW India Ltd. cannot be excluded on this
count. But for that, the assessee has not disputed the otherwise
functional and other similarities with ITW India Limited. We,
therefore, jettison the assessee‟s contention for exclusion of ITW
India Limited from the list of comparables. The impugned order is
accorded imprimatur on this issue.
IV. PROPORTIONATE ADJUSTMENT
7.1. The last issue which survives in this appeal is against the
proportionate transfer pricing adjustment. It is seen that the TPO
recommended the transfer pricing adjustment by considering the
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entity level figures of the assessee under the TNMM without
restricting it to the international transactions.
7.2. The issue of restricting the transfer pricing adjustment to the
transaction level rather than the entity level is no more res integra in
view of several judgments rendered by various higher forums
including the Hon‟ble jurisdictional High Court holding that the
transfer pricing adjustment should be restricted only to the
international transactions and not the entity level transactions. The
Hon‟ble jurisdictional High Court in CIT Vs. Phoenix Mecano
(India) Pvt. Ltd. (2019) 414 ITR 704 (Bom.) has held that the
transfer pricing adjustment made at entity level should be restricted
to the international transactions only. Here, it is pertinent to
mention that the Department‟s SLP against the judgment in the case
of Phoenix Mecano (India) Pvt. Ltd. has since been dismissed by
the Hon‟ble Supreme Court in CIT Vs. Phoenix Mecano (India) Pvt.
Ltd. (2018) 402 ITR 32 (St.). Similar view has been taken by the
Hon‟ble Bombay High Court in CIT Vs. Thyssen Krupp Industries
Pvt. Ltd. (2016) 381 ITR 413 (Bom.) and CIT Vs. Tara Jewels
Exports (P). Ltd. (2010) 381 ITR 404 (Bom.). We, therefore, set
aside the impugned order on this score and direct that the transfer
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pricing adjustment should be restricted only to the value of
international transactions.
8. To sum up, the impugned order on the issue of transfer pricing
adjustment of the international transactions of Purchase of raw
material and Sale of finished goods is set aside and the matter is
remitted to the file of the AO/TPO for a fresh determination in the
terms indicated above. Needless to say, the assessee will be
allowed reasonable opportunity of hearing in such fresh
proceedings.
9. In the result, the appeal is allowed for statistical purposes.
Order pronounced in the Open Court on 1st November, 2021.
Sd/- Sd/-
(PARTHA SARATHI CHAUDHURY) (R.S.SYAL)
JUDICIAL MEMBER VICE PRESIDENT
पुणे Pune; ददन ां क Dated : 1st November, 2021
सतीश/GCVSR
आदे श की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to:
1. अपील थी / The Appellant;
2. The Respondent
3. प्रत्यथी / The CIT(A)-13, Pune
4. The PCIT-5, Pune
5. DR, ITAT, „C‟ Bench, Pune
6. ग र्ड फ ईल / Guard file.
आदे शानुसार/ BY ORDER,
// True Copy //
Senior Private Secretary
आयकर अपीलीय अदधकरण ,पुणे / ITAT, Pune
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Date
1. Draft dictated on 29-10-2021 Sr.PS
2. Draft placed before author 01-11-2021 Sr.PS
3. Draft proposed & placed before JM
the second member
4. Draft discussed/approved by JM
Second Member.
5. Approved Draft comes to the Sr.PS
Sr.PS/PS
6. Kept for pronouncement on Sr.PS
7. Date of uploading order Sr.PS
8. File sent to the Bench Clerk Sr.PS
9. Date on which file goes to the
Head Clerk
10. Date on which file goes to the
A.R.
11. Date of dispatch of Order.
*
Comments