Transfer pricing adjustment made to alleged international...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to incur such expenditure on behalf of parent company or that advertising and marketing budget was determined by parent entity. TP adjustments to arm's length price of international transactions in Trading segment under TNMM by altering set of comparable companies upheld as deselection of functionally dissimilar companies justified. Similarly, TP adjustments in Networking segment upheld. TPO directed to grant working capital adjustment and correctly compute profit margins of comparables by excluding non-operational items while determining arm's length price in Trading, Networking and Manufacturing segments. TPO also directed to determine proportionate adjustment appropriately by considering transactions with AEs and excluding unrelated party transactions. Adjustment to royalty paid to parent for licensed know-how deleted as TPO's selection of comparable transactions under CUP lacked meaningful comparability and was arbitrary. Adoption of TNMM held appropriate as relevant CUP data unavailable. Disallowance of salary paid to expatriate employees on secondment from Korea deleted as they worked under sole control of assessee and no evidence of furthering parent company's objectives.