Transfer pricing margins to be redetermined: include export incentives, cash discounts, miscellaneous expenses, and specific segmental comparables

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The ITAT allowed the appeal in part and directed the TPO/AO to re-determine transfer pricing margins: export incentives (e.g., duty drawback, export incentives) and cash discount income are to be treated as operating revenue for the assessee and included in margin computations; miscellaneous expenses are operating in nature and must be included in operating expenses of comparables where applicable; for a specified comparable with audited segmental reporting, only the auto-component segment shall be used rather than entity-level results; three additional comparables identified by the assessee are to be included in the final comparable set. The ITAT remitted the matter for compliance consistent with these rulings.....