https://www.taxtmi.com/caselaws?id=759827 The Delhi HC upheld ITAT's decision on transfer pricing adjustments for pharmaceutical transactions. For Paclitaxel and Disodium Pamidronate sales, the court accepted TNMM over CUP method, noting TPO failed to consider Rule 10B(2) factors and relied on different market prices. Net margins from these sales were higher at 14.10% versus 10.90% for other sales. For Methylene Chloride Soluble purchase from associated enterprise, despite TPO's Rs. 32 per kg determination using CUP method, the assessee's cost certificate showing Rs. 4648 per kg was accepted by CIT(A). The appellant failed to challenge the cost certificate's veracity before ITAT. HC found no substantial question of law arose from these factual determinations. en-us Mon, 05 Feb 2024 00:00:00 +0530 Wed, 09 Oct 2024 08:20:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759827 The Delhi HC upheld ITAT's decision on transfer pricing adjustments for pharmaceutical transactions. For Paclitaxel and Disodium Pamidronate sales, the court accepted TNMM over CUP method, noting TPO failed to consider Rule 10B(2) factors and relied on different market prices. Net margins from these sales were higher at 14.10% versus 10.90% for other sales. For Methylene Chloride Soluble purchase from associated enterprise, despite TPO's Rs. 32 per kg determination using CUP method, the assessee's cost certificate showing Rs. 4648 per kg was accepted by CIT(A). The appellant failed to challenge the cost certificate's veracity before ITAT. HC found no substantial question of law arose from these factual determinations. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759827