M/S INSTRUMENTARIUM CORPORATION LTD.,KOLKATA vs. DDIT (IT)-1(1), KOLKATA, KOLKATA

Bench: The Special Bench:

Transfer Pricing Regulations of India, in particular to the case of the assessee? (3) Whether, setting off of loss with

ORGANON (INDIA) LIMITED,MUMBAI vs. ADDL. CIT, CIRCLE - 12, KOLKATA, KOLKATA

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

Bench: Shri P.M. Jagtap, Vice-(Kz) & Shri A.T. Varkey

Loss Account, the Transfer Pricing Officer found that administrative and other allocable expenses had not been allocated by the assessee to the segment, wherein sales were made to the Associated Enterprises and the same were entirely allocated to the segments where sales were made to the unrelated parties. He also found that operating margin to sales in case of sale