DRP's 10% Transfer Pricing Adjustment Overturned for Non-Compliance with Section 92C(1) and Lack of Benchmarking.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Ad hoc addition of 10% under transfer pricing adjustment - the adjustment of 10% so upheld by the DRP was without following any of the prescribed methods U/s 92C(1) of the Act nor has any benchmarking been adopted in determination of the ALP - entire addition deleted.....