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5.7. The factors referred to above are to be applied cumulatively in selecting the most appropriate method. The reference therein to the terms 'best suited' and 'most reliable C.O.-10/Kol/2016 Data Core India Pvt. Ltd.

A.Yrs.2010-11 & 2011-12 measure' indicates that the most appropriate method will have to be selected after a meticulous appraisal of the facts and circumstances of the international transaction or specified domestic transaction. Further, the selection of the most appropriate method shall be for each particular international transaction or specified domestic transaction. The term 'transaction' itself is defined in Rule 10A(d) to include a number of closely linked transactions. Therefore, though the reference is to apply the most appropriate method to each particular transaction, keeping in view , the definition of the term 'transaction', the most appropriate method may be chosen for a group of closely linked transactions. Two or more transactions could be said to be linked when these transactions emanate from a common source being an order or a contract or an agreement or an arrangement and the nature , characteristics and terms of these transactions are substantially flowing from the said common source. For example, a master purchase order is issued stating the various terms and conditions and subsequently, individual orders are released for specific quantities. The various purchase transactions are closely linked transactions.

A.Yrs.2010-11 & 2011-12 parameters in a water tight compartment as to what transactions can be considered as 'closely linked', since the same would depend on facts and circumstances of each case. So however, as per an example noted by the Institute of Chartered Accountants of India (in short the 'ICAI') in its Guidance Notes on transfer pricing in para 13.7, it is stated that two or more transactions can be said to be 'closely linked', if they emanate from a common source, being an order or contract or an agreement or an arrangement, and the nature, characteristic and terms of such transactions substantially flow from the said common source. The following extract from the said Guidance Notes is worthy of notice:-

"13.7. ................
13.8. ........................
26. In view of the ratio laid down by Pune Bench of the Tribunal in Demag Cranes & Components (India) (P.) Ltd. (supra), it is held that where number of transactions are closely linked transactions, then the same can be aggregated and construed as a single transaction for the purpose of determining the arm's length price. In case, there is close link exists between the different transactions, the same should be treated as composite transaction and appropriate method should be applied to work out the transfer pricing analysis. Where two or more transactions emanate from common source being an order or contract or an agreement or an arrangement, then such transactions could be said to be closely linked as the nature, characteristic and terms of such transaction substantially flow from the said common source.

6.12. It is also relevant to note that no adjustments to ALP had been made by the ld TPO in the earlier years in assessee's own case pursuant to the same composite contract entered into with effect from 1.4.2008 relevant to Asst Year 2009-10.

6.13. We find that the ld DRP had directed the ld TPO to adopt the comparables from the SD segment also while arriving at the ALP margin. This goes to prove that the ld DRP had accepted the stand that the assessee is rendering both IT and ITES services to its AE emanating from a common source of a composite agreement. Against this direction, the revenue is not in appeal before us. Hence it could be safely concluded that the fact of assessee rendering both IT and ITES services to its AE pursuant to a composite agreement has been accepted by the C.O.-10/Kol/2016 Data Core India Pvt. Ltd.