Section 92C(2) specifies that adjustment of 5% is not applicable if a singl

Section 92C(2) specifies that adjustment of 5% is not applicable if a single price is determined by assessee

Income-tax : Where the ALP has been determined by applying only one out of the several methods specified under section 92C(1) the assessee is not entitled for deduction of 5% adjustment from the ALP as stipulated under section 92C(2) [Section 92C of the Income-tax Act, 1961 - Transfer Pricing] - [2011] 10 taxmann.com 160 (Hyd. - ITAT)

Transfer Pricing (Section 92C) - Lack of segmental reporting for re

Income-tax : Transfer Pricing (Section 92C) - Lack of segmental reporting for reason that transactions with AEs and non-AEs belong to same item of software related services, cannot be made a basis for rejecting assessee's method of computing Arm's Length Price by way of internal comparison made between transaction with AEs and unrelated parties. - [2011] 9 taxmann.com 263 (Delhi - ITAT)