THE PRINCIPAL COMMISSIONER OF INCOME TAX 4 MUMBAI vs. M/S S.G. ASIA HOLDINGS (INDIA) PVT. LTD

The Appeal is allowed to the aforesaid extent

Bench: HON'BLE THE CHIEF JUSTICE

transfer price has to be determined by the TPO in terms of section 92C. The price has to be determined by any one of the methods stipulated in sub-section (1) of section 92C and by applying the most appropriate method referred to in sub-section (2) thereof. There may be occasions where application of the most appropriate method provides

ASSTT DIRECTOR OF INCOME TAX I NEW DELHI vs. M/S E FUNDS IT SOLUTION INC

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

TP Report states as follows: “The President’s office manages the operations of eFunds India and eFunds group entities in UK and Australia and accordingly, employees of these entities report to the President. The President’s overall reporting is to EFC. 11 Though the personnel rendering marketing services are employees of EFI, they report to overseas group entities