https://www.taxtmi.com/caselaws?id=267466 Transfer pricing adjustment on mineral exports, including Barite Lumps, was rejected because the revenue's month-wise third-party comparison and FOB-to-CIF comparison were found unreliable, with differing quantities, commercial terms and quality variations making the benchmarking unsuitable; the earlier year's reasoning in the assessee's own case was followed, and the deletion of the adjustment was sustained. Amounts paid to Andhra Pradesh Mineral Development Corporation were held to be compensatory for credit period used in purchasing goods, not interest on a loan, debt or deposit, so they fell outside section 2(28A) and no TDS disallowance arose; the deletion of the disallowance was upheld. en-us Thu, 29 Oct 2015 00:00:00 +0530 Thu, 05 Nov 2015 22:05:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=267466 Transfer pricing adjustment on mineral exports, including Barite Lumps, was rejected because the revenue's month-wise third-party comparison and FOB-to-CIF comparison were found unreliable, with differing quantities, commercial terms and quality variations making the benchmarking unsuitable; the earlier year's reasoning in the assessee's own case was followed, and the deletion of the adjustment was sustained. Amounts paid to Andhra Pradesh Mineral Development Corporation were held to be compensatory for credit period used in purchasing goods, not interest on a loan, debt or deposit, so they fell outside section 2(28A) and no TDS disallowance arose; the deletion of the disallowance was upheld. Case-Laws Income Tax Thu, 29 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=267466