2017 (11) TMI 1806 - SCH - Income Tax

Transfer pricing adjustment - bench marking - royalty and technical assistance fee did not form part of a composite transaction and have to be treated as two separate transactions for the purpose of benchmarking and computing arms length price - transactional Net Margin Method applied for benchmarking/computing arm s length price in respect of transaction relating to technical assistance fee - HELD THAT - SLP dismissed.

Summary

Title: Supreme Court of India dismisses special leave petition

Judges: Rohinton Fali Nariman and Sanjay Kishan Kaul

Petitioner's Counsel: Sarad Kumar Singhaania, Manish Pushkarna, Mrs. Anil Katiyar

Respondent's Counsel: S. Ganesh, Anand Sukumar, S. Sukumaran, Bhupesh Kumar Pathak, Ms. Meera Mathur

Decision: Delay condoned, special leave petition dismissed, pending applications disposed of