Syngene's Transfer Pricing Battle: Comparables, AMP Expenses, and Margins Scrutinized in Complex Tax Dispute

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ITAT adjudicated multiple transfer pricing issues, primarily focusing on comparability and arm's length pricing. The tribunal upheld the deletion of AMP expenditure additions, finding no international transaction. The court rejected Syngene International Limited as a comparable due to unavailable segmental information. Sequent Research Limited was accepted as a valid comparable. Regarding interest on external commercial borrowings, the tribunal remanded the matter to obtain proper credit ratings, agreeing that LIBOR was an appropriate benchmarking method. The TP adjustment on raw material purchases was deleted after analyzing gross margins, with the assessee's margin of 54.59% deemed acceptable compared to the comparable companies' median of 35.28%. Most revenue grounds were dismissed, with appeals allowed for statistical purposes.....