“specified domestic transaction”

Transfer PricingSection 92BASection 92BA588 judgments

The decision most relied on for specified domestic transaction is CIT v. ITC Ltd. (236 Taxmann 612), cited in 108 judgments on BharatTax.

Leading authorities on specified domestic transaction

CIT v. ITC Ltd.

236 Taxmann 612 · 2016 · High Court

108

citing judgments

When computing deduction under Section 80IA, specifically for inter-unit transfer of power, the benefit cannot be claimed based on rates chargeable by distribution licensees to consumers. The deduction must be computed based on the rate fixed by the Tariff Regulation Commission for sale by electricity generating companies.

CIT v. Godawari Power & Ispat Ltd.

42 Taxmann.com 551 · 2014 · High Court

104

citing judgments

Inter-unit transfer of power by an industrial undertaking eligible for Section 80IA deduction constitutes a specified domestic transaction under Section 92BA, requiring valuation at arm's length. This decision clarifies the application of Section 80IA(8) and transfer pricing regulations for such transactions.

CIT v. Jindal Steel & Power Ltd.

157 Taxmann.com 207 · 2023 · Supreme Court

citing judgments

For Section 80IA deductions, the market value of electricity supplied by a captive power plant (eligible unit) to its industrial unit (non-eligible unit) must be computed by comparing prices in the open market and those charged by State Electricity Boards to industrial consumers.

CIT v. Shatrunjay Diamonds

261 ITR 258 · 2003 · High Court

citing judgments

The assessee bears the initial burden to maintain and produce authentic documentation under Section 92D and Rule 10D to justify transactions with related parties, especially concerning the arm's length price for such transactions under Section 40A(2)(b). The discharge of this statutory obligation to maintain accurate data is a mandatory requirement of law.

Commissioner of Income Tax v. Gujarat Alkalies Chemicals Limited

395 ITR 247 · 2017 · High Court

citing judgments

Deduction under Section 80IA is allowable for captive power generation. The price for calculating this deduction is the rate at which the electricity board supplies power to its consumers, rather than the rate at which power generating companies supply to the electricity board.

Skoda Auto India (P) Ltd. v. ACIT, Aurangabad

30 SOT 319 · 2009 · ITAT

citing judgments

The Tribunal may allow adjustments for differences between the tested party and comparable companies to eliminate material differences, provided accurate and credible evidence is furnished.

M/s. Shree Bhagwati Steel Rolling Mills v. C.I.T. Excise & Others

62 Taxmann.com 135 · 2015 · Supreme Court

citing judgments

Judgments in M/s. Shree Bhagwati Steel Rolling Mills and M/s. Fibre Boards have overruled earlier decisions, preventing assessees from relying on those overruled precedents.

CIT v. Star Paper Mills Ltd.

172 Taxmann.com 391 · 2025 · High Court

citing judgments

The transfer price for intra-group services, specifically the sale of power from a captive power plant to a manufacturing unit, can be benchmarked based on the price at which the manufacturing unit procures power from the State Electricity Board, especially when it reflects a reasonable and arm's length price.

Judgments citing specified domestic transaction

ACIT 6(3), Mumbai vs. Mylan Developemtnt Centre P.Ltd ( Formelry Merck Development Centre P.Ltd ), Mumbai

In the result, both the appeal of the assessee and Revenue is partly allowed and the cross-objection of the assessee is dismissed

ITA 1283/MUM/2012[2007-08]Status: DisposedITAT Mumbai28 Jul 2022AY 2007-08

For Appellant: Ms. Hirali Desai/AmolFor Respondent: Shri Ankush Kalra

prices: Provided further that if the variation between the arm's length price so determined and price at which the international transaction [or specified domestic transaction] has actually been undertaken [does not exceed [such percentage of the latter, as may be notified] by the Central Government in the Official Gazette ... this behalf], the price at which the international transaction [or specified domestic transaction] has actually been undertaken shall be deemed to be the arm's length price.] [Explanation.—For the removal of doubts, it is hereby clarified that the provisions of the second proviso shall also be applicable

Lg Soft India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 266/BANG/2021[2016-17]Status: DisposedITAT Bangalore28 Jul 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Rashmi R., A.RFor Respondent: Shri Praveen Karanth, D.R

Section 143(3)

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely ;— ** *ft (a) to (b)** (e) transactional ... margin method, by which,— (I) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] .entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise or having

M/S Quicklogic Software (India) Pvt. Ltd., Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bengaluru

In the result, the appeal filed by the assessee stands partly allowed

ITA 181/BANG/2022[2017-18]Status: DisposedITAT Bangalore27 Jul 2022AY 2017-18

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 181/Bang/2022 Assessment Year : 2017-18 M/S. Quicklogic Software (India) Pvt. Ltd., No. 10 Brindavan, The Deputy 3Rd Floor, Commissioner Of Yashoda Nagar Main Income Tax, Road, Circle 3(1)(1), Jakkur Plantation, Vs. Bangalore. Bengaluru – 560 064. Pan: Aaacq0656P Appellant Respondent Assessee By : Shri Mahaveer C Jain, Ca : Shri Sumer Singh Meena Cit Revenue By Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 27-07-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 25/01/2022 By The National Faceless Assessment Centre For A.Y. 2017-18 On Following Revised Grounds Of Appeal:

For Appellant: Shri Mahaveer C Jain, CA

Section 142(1)Section 143(2)Section 92C

determining ALP vide S.O. No. 2860 (E) dated 19/10/2015. The amended regime will be applicable for computation of ALP of international transactions and specified domestic transactions Page 19 IT(TP)A No. 181/Bang/2022 undertaken on or after 1/04/2014 i.e. on and after PY 2014-15. The amended rules allow ... read as follows: "Computation of arm's length price in certain cases. 10CA. (1) Where in respect of an international transaction or a specified domestic transaction, the application of the most appropriate method referred to in sub-section (1) of section 92C results in determination of more than one price

M/S. Sulzer Tech India P. Ltd., Navi Mumbai vs. Addl./Jt./ Dy./ Asstt. CIT/ Income Tax Officer, Delhi

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 633/MUM/2021[2016-17]Status: DisposedITAT Mumbai25 Jul 2022AY 2016-17

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Ravi Saeana a/wFor Respondent: Shri Tejinder Pal Singh

Section 143(3)Section 144C(13)Section 92CSection 92C(1)

section 92C, the other method for determination of the arm's length price in relation to an international transaction or a specified domestic transaction shall be any method which takes into account the price which has been charged or paid, or would have been charged or paid, for the same

Giraffe Developers Pvt. Ltd., Mumbai vs. Pr. CIT - 9, Mumbai

In the result, the appeal filed by the assessee is partly allowed

ITA 2663/MUM/2019[2014-15]Status: DisposedITAT Mumbai25 Jul 2022AY 2014-15

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalegiraffe Developers Pvt Vs. Pr. Cit – 9, Ltd Room No. 214, 2Nd 111, G Wing, Akruti Floor, Aayakar Commercial Complex, Bhavan, M.K. Road, Next To Akruti Centre Churchgate, Point, Central Road, Mumbai-400020. Andheri (E), Mumbai- 400093 Pan/Gir No. : Aaccn2778D Appellant .. Respondent Appellant By : Shri.Madhur Agrawal & Shri.Fenil Bhatt.Ar Respondent By : Shri.S.Anbuselvam.Dr Date Of Hearing 13.07.2022 Date Of Pronouncement 25.07.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of Pr. Commissioner Of Income Tax (Appeals)-9, Mumbai Passed U/S 143(3) & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Madhur Agrawal &For Respondent: Shri.S.Anbuselvam.DR

Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 271ASection 271BSection 40Section 40A(2)Section 92D

failure to report payment of interest on Rs.15,00,00,000 amounting to Rs. 15,00,00,000/- to Hubtown Limited as a Specified Domestic Transaction under the provisions of Section 92D of the Income Tax Act. 6. On the facts and circumstances of the case ... Further, the assessee has paid amounting to Rs. 15 crores as interest on debenture and it should have been reported as Specified Domestic Transaction. Accordingly, section 271AA for failure to report the specified domestic transaction u/s 92D(1) and section 271 BA for its failure to furnish the audit report

Cisco Systems Capital (India) Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 321/BANG/2022[2017-18]Status: DisposedITAT Bangalore21 Jul 2022AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Rajan Vora, A.RFor Respondent: Shri G. Manoj Kumar, D.R

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144C(5)

assessee are reproduced as under:- “B. Grounds of appeal in relation to transfer pricing matters Initiating scrutiny proceedings in relation to Specified domestic transaction, not considering amendment made by Finance Act - 2017 7. The learned AO/TPO has erred in law and fact, by initiating scrutiny proceedings in relation ... specified domestic transaction of payment made by the Appellant towards the fees for administrative support services to the AE. disregarding the deletion of clause (i) of IT(TP)A No.321/Bang/2022 Cisco Systems Capital (India) Private Ltd., Bangalore Page 9 of 19 section 92BA of the Act by virtue of amendment

DCIT - 3(3)(2), Mumbai vs. V. Hotels Ltd.(Formerly Known As Tulip Hospitality Services Ltd), Mumbai

In the result, all the appeals filed by the revenue are dismissed

ITA 5664/MUM/2018[2013-14]Status: DisposedITAT Mumbai20 Jul 2022AY 2013-14

Section 32(1)(ii)

account of any expenditure being excessive or unreasonable having regard to the fair market value, shall be made in respect of a specified domestic transaction referred to in Section 928A, if such transaction is at arm's length price as defined in clause (11) of Section 92F. As provided under

DCIT - 3(3)(2), Mumbai vs. V. Hotels Ltd.(Formerly Known As Tulip Hospitality Services Ltd), Mumbai

In the result, all the appeals filed by the revenue are dismissed

ITA 5663/MUM/2018[2013-14]Status: DisposedITAT Mumbai20 Jul 2022AY 2013-14

Section 32(1)(ii)

DCIT - 3(3)(2), Mumbai vs. V. Hotels Ltd.(Formerly Known As Tulip Hospitality Services Ltd), Mumbai

In the result, all the appeals filed by the revenue are dismissed

ITA 5662/MUM/2018[2012-13]Status: DisposedITAT Mumbai20 Jul 2022AY 2012-13

Section 32(1)(ii)

M/S Te Connectivity India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

In the result, the appeal by the assessee is partly allowed

ITA 2680/BANG/2017[2013-14]Status: DisposedITAT Bangalore18 Jul 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri Sumeet Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 143(3)Section 40Section 92

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— ****** (e) transactional net margin method, by which ... No.2680/Bang/2017 Page 15 of 50 (i) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise

Mutha Engineering Pvt. Ltd., Mumbai vs. The Dy. Commissioner of Income Tax Circle 4 (2)(2), Mumbai

In the result, appeal by the assessee is partly allowed in terms indicated above

ITA 7226/MUM/2018[2014-15]Status: DisposedITAT Mumbai13 Jul 2022AY 2014-15

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri G.P. MehtaFor Respondent: Shri Tejinder Pal Singh Anand

Section 143(3)Section 144C(5)Section 40ASection 92B

No.7226/Mum./2018 2. In the present appeal, the assessee is aggrieved against the adjustment of Rs.5,23,79,628, in respect of specified domestic transactions entered into by the assessee. 2. When this appeal came up for hearing, the learned Representative appearing for the parties fairly agreed that the aforesaid ... that case, the coordinate bench held that the adjustment on account of examination of the arm's-length price of the specified domestic transactions is not valid because of deletion of the provisions of Section 92BA (1) of the act with effect from 1/4/2017 without any saving clause

Dwarikesh Sugar Industries Ltd, Mumbai vs. Assessing Officer, NFAC, Mumbai

ITA 562/MUM/2022[2017-18]Status: DisposedITAT Mumbai05 Jul 2022AY 2017-18

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2017-18 M/S. Dwarikesh Sugar The Assessing Officer, Industries Ltd., National Faceless 511, Maker Chamber – V, Vs. Assessment Centre, 211, Nariman Point, Delhi Mumbai – 400 021 Pan: Aabcd 8192N (Appellant) (Respondent)

For Appellant: Shri Jayesh Dadia, A.RFor Respondent: Shri Sambit Mishra, D.R

Section 143Section 143(3)Section 144BSection 144CSection 234Section 253Section 270A

residue or a by-product of sugar production process. During the year under 3 M/s. Dwarikesh Sugar Industries Ltd. assessment assessee entered into specified domestic transactions as reported in form 3CEB viz. power transfer to sugar units, stream transfer to sugar units, purchase of raw materials and allocation of expenses ... Partly declining the transfer pricing study conducted by the assessee as to finding its specified domestic transactions at arms length the Ld. Transfer Pricing Officer (TPO) proceeded to make adjustment of Rs.39,84,42,988/- towards profit of eligible units, which represents the amount of profit attributable to non eligible

M/S Tokai Rika Minda India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Cicle-7(1)(1), Bangalore

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 1513/BANG/2017[2013-14]Status: DisposedITAT Bangalore29 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R

Section 143(3)Section 92CSection 92C(2)

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely ; (a) to (b)** (e) transactional net margin ... method, by which,- (i) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] entered into with an associated enterprise is computed in relation to costs IT(TP)A No.1513/Bang/2017 M/s. Tokai Rika Minda India Pvt. Ltd., Nelamangala Taluk Page

M/S Rittal India Pvt Ltd, Doddaballapur vs. Assistant Commissioner of Income Tax Circle-2, Ltu, Bangalore

In the result, the appeal of the assessee is allowed

ITA 2868/BANG/2018[2014-15]Status: DisposedITAT Bangalore28 Jun 2022AY 2014-15

Bench: Shri N.V Vasudevan & Ms. Padmavathy S

For Appellant: Shri Ramasubramaniam, C.AFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)

Section 143(3)Section 92Section 92C

Reference to Transfer Pricing Officer (TPO) 3.1 The power to determine the Arm's Length Price (ALP) in an international transaction or specified domestic transaction is contained in sub-section (3) of section 92C. However, section 92CA provides that where the Assessing Officer (AO) considers it necessary or expedient ... refer the computation of ALP in relation to an international transaction or specified domestic transaction to the TPO. For proper administration of the Income-tax Act, the Board has decided that the AO shall henceforth make a reference to the TPO only under the circumstances laid out in this Instruction

Mindteck (India) Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 252/BANG/2021[2016-17]Status: DisposedITAT Bangalore27 Jun 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.252/Bang/2021 Assessment Year : 2016-17 M/S. Mindteck India Ltd., Vs. Dcit, A.M.R. Tech Park, Block 1, 3Rd Floor, Circle – 4(1)(1), No.664, 23/24, Hosur Main Road, Begur, Bengaluru. Bengaluru-560 068. Pan : Aaach 1072 Q Appellant Respondent Assessee By : Shri. Padam Chand Khincha, Ca Revenue By : Shri. V. S. Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 20.06.2022 Date Of Pronouncement : 27.06.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. V. S. Chakrapani, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92(1)Section 92B(1)

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— (a) to (d).... (e)transactional net margin ... clause (ii) arising in comparable uncontrolled transactions is adjusted to take into account the differences, if any, between the international transaction [or the specified domestic transaction] and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect the amount of net profit margin

M/S. Walvoil Fluid Power (India) Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 7(1)(2), Bengaluru

In the result, the appeal by the assessee is partly allowed

ITA 1839/BANG/2019[2007-08]Status: DisposedITAT Bangalore27 Jun 2022AY 2007-08

Bench: Smt. Beena Pillai & Ms. Padmavathy S

For Appellant: Shri R.E. Balasubramaniyan, CAFor Respondent: Smt. Susan Dolores George, CIT(OSD)(DR)

Section 143(3)Section 154Section 92C

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— IT(TP)A No.1839/Bang/2019 Page ... transactional net margin method, by which,— (i) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by the enterprise

Edelweiss Commodities Services Ltd, Mumbai vs. DCIT, CC-1(1), Mumbai

In the result, the appeal filed by the assessee is treated as allowed

ITA 7475/MUM/2017[2013-14]Status: DisposedITAT Mumbai24 Jun 2022AY 2013-14

Section 115JSection 143(3)Section 144CSection 14A

Disallowance of mark to market losses b) Disallowance made under section 14A of the Act c) Transfer pricing adjustment in respect of specified domestic transactions d) Validity of the assessment order on the ground that it is time barred e) Short credit of TDS 2 Edelweiss Rural & Corporate Services Limited ... 115JB of the Act. 15. The next issue urged by the assessee relates to the transfer pricing adjustment made in respect of specified domestic transactions. The TPO had proposed transfer pricing adjustment of Rs.15,43,05,000/-. The Ld DRP reduced the same to Rs.9,18,05,000/-. 16. Without

M/S. Citrix R & D India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 2(1)(1), Bangalore

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 2428/BANG/2019[2015-16]Status: DisposedITAT Bangalore15 Jun 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri Sumeet Khurana, A.RFor Respondent: Ms. Neera Malhotra, D.R

purposes of sub-section (2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :--- (a) to (d)…………. (e)transactional net margin ... method, by which,— (i) the net profit margin realised by the enterprise from an international transaction [or a specified domestic transaction] entered into with an associated enterprise is computed in relation to costs incurred or sales effected or assets employed or to be employed by 'the enterprise or having regard

M/S. Himalaya Wellness Company (Formerly Known As the Himalaya Drug Company), Bengaluru vs. The Deputy Commissioner of Income Tax, Circle- 6(1)(1), Bengaluru

In the result, the appeal filed by the assessee is partly allowed for statistical purpose

ITA 259/BANG/2022[2017-18]Status: DisposedITAT Bangalore14 Jun 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.259/Bang/2022 : Asst.Year 2017-2018 M/S.Himalaya Wellness Company The Deputy Commissioner Of (Formerly Known As The Himalaya Income-Tax, Circle 6(1)(1) V. Bengaluru. Drug Company), Makali, Tumkur Road Bengaluru – 562 162. Pan : Aadft3025B. (Appellant) (Respondent)

For Appellant: Sri.Padamchand Kincha, CAFor Respondent: Sri.Sumer Singh Meena, CIT -DR

Section 143(1)Section 143(2)Section 143(3)Section 144C(5)Section 2(11)Section 92C

clause (ii) is adjusted to take into account the functional and other differences, if any, between the international transaction or the specified domestic transaction and the comparable uncontrolled transactions, or between the enterprises entering into such transactions, which could materially affect such profit mark-up in the open market

Enstage Software Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

The appeal of the assessee is partly allowed

ITA 260/BANG/2021[2016-17]Status: DisposedITAT Bangalore13 Jun 2022AY 2016-17

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.260/Bang/2021 Assessment Year : 2016-17 M/S. Enstage Software Private Limited, Dcit (Exemptions), Vs. 16/1, Wings, 2Nd Floor, Circle – 2(1)(1), Cambridge Road, Halsuru, Bengaluru. Bengaluru – 560 008. Pan : Aaace 9963 B Appellant Respondent

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Smt. Susan Dolores George, CIT(OSD)(DR)(ITAT), Bengaluru

Section 143(3)Section 92(1)Section 92B(1)Section 92C

determining ALP vide S.O. No. 2860 (E) dated 19/10/2015. The amended regime will be applicable for computation of ALP of international transactions and specified domestic transactions undertaken on or after 1/04/2014 i.e. on and after PY 2014-15. The amended rules allow for introduction of a “range concept” for determination ... read as follows: “Computation of arm's length price in certain cases. 10CA. (1) Where in respect of an international transaction or a specified domestic transaction, the application of the most appropriate method referred to in sub-section (1) of section 92C results in determination of more than one price