Shanti Prime Publication Pvt. Ltd.
Section 92CA of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price— TPO was justified in discarding the assessee's version and determing the ALP in his own way as assessee having failed to produce the financials of the tested parties and the companies chosen as comparable and produced only some certificate from the AE. Profit on sales made in india to non AEs cannot be accepted as a comparable instance for determining the ALP of the international transactions including exports made to the AEs in Brazil and USA for lack of the provision by the assessee of any data offloading the effect of such geographical difference in the profit margins — Eaton Industrial Systems P. Ltd. vs. Deputy Commissioner of income tax [2020] 203 TTJ (Pune) 1