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The ITAT allowed the appeal in part and directed the TPO/AO to re-determine transfer pricing margins: export incentives (e.g., duty drawback, export incentives) and cash discount income are to be treated as operating revenue for the assessee and included in margin computations; miscellaneous expenses are operating in nature and must be included in operating expenses of comparables where applicable; for a specified comparable with audited segmental reporting, only the auto-component segment shall be used rather than entity-level results; three additional comparables identified by the assessee are to be included in the final comparable set. The ITAT remitted the matter for compliance consistent with these rulings.
The ITAT allowed the appeal in part and directed the TPO/AO to re-determine transfer pricing margins: export incentives (e.g., duty drawback, export incentives) and cash discount income are to be treated as operating revenue for the assessee and included in margin computations; miscellaneous expenses are operating in nature and must be included in operating expenses of comparables where applicable; for a specified comparable with audited segmental reporting, only the auto-component segment shall be used rather than entity-level results; three additional comparables identified by the assessee are to be included in the final comparable set. The ITAT remitted the matter for compliance consistent with these rulings.
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