SECTION 92CA: COMPUTATION OF ARM LENGTH PRICE

The Bangalore ITAT bench has held that there may be variations/difference in activities of both assessee and comparables from year to year requiring appropriate TP adjustment.

The Bangalore ITAT bench has held that super profit making companies and companies with functional differences are to be excluded from list of comparables while making transfer pricing
adjustment.

The Bangalore ITAT bench has held that TP provisions do not require TPO to establish a motive of transferring profits out of India prior to finding out as to whether assessee's inter-national transactions are at arm's length or not.