https://www.taxtmi.com/caselaws?id=353992 A transfer pricing adjustment requires a real international transaction and computation under a prescribed statutory method. The write-off of obsolete stock-in-trade was treated as a commercial decision after the goods became unsaleable, and the distribution agreement did not create any obligation on the associated enterprise to reimburse such stock; the addition was therefore deleted. The alleged provision of market information services was also not established on the record, and an ad hoc percentage-based adjustment without applying the transfer pricing methods under Chapter X was impermissible; that adjustment was likewise deleted. Both transfer pricing additions were set aside and the assessee succeeded. en-us Fri, 12 Jan 2018 00:00:00 +0530 Tue, 16 Jan 2018 09:25:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=353992 A transfer pricing adjustment requires a real international transaction and computation under a prescribed statutory method. The write-off of obsolete stock-in-trade was treated as a commercial decision after the goods became unsaleable, and the distribution agreement did not create any obligation on the associated enterprise to reimburse such stock; the addition was therefore deleted. The alleged provision of market information services was also not established on the record, and an ad hoc percentage-based adjustment without applying the transfer pricing methods under Chapter X was impermissible; that adjustment was likewise deleted. Both transfer pricing additions were set aside and the assessee succeeded. Case-Laws Income Tax Fri, 12 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=353992