https://www.taxtmi.com/caselaws?id=204648 The appeal was against the CIT(A)'s order confirming an upward adjustment in international transaction pricing for the assessment year 2004-05. The Assessing Officer proposed the adjustment under section 92C(3) based on low operating margin, comparing the appellant's profit with similar companies. The A.O. considered the appellant's transaction with its holding company, where the appellant showed a net profit of 3.26%, turning negative when excluding other income. The CIT(A) upheld the adjustment, emphasizing the appellant's status as a subsidiary of a foreign enterprise and the need for fair comparison, leading to the tribunal remanding the matter for fresh adjudication. en-us Fri, 17 Jun 2011 00:00:00 +0530 Fri, 23 Sep 2011 08:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204648 The appeal was against the CIT(A)'s order confirming an upward adjustment in international transaction pricing for the assessment year 2004-05. The Assessing Officer proposed the adjustment under section 92C(3) based on low operating margin, comparing the appellant's profit with similar companies. The A.O. considered the appellant's transaction with its holding company, where the appellant showed a net profit of 3.26%, turning negative when excluding other income. The CIT(A) upheld the adjustment, emphasizing the appellant's status as a subsidiary of a foreign enterprise and the need for fair comparison, leading to the tribunal remanding the matter for fresh adjudication. Case-Laws Income Tax Fri, 17 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204648