Jaipur Tax Tribunal Quashes Major Transfer Pricing Adjustments For Jewellery Maker
The Jaipur bench of the Income Tax Appellate Tribunal ruled that the Berry ratio does not apply to a full-fledged jewellery manufacturer. Consequently, it deleted transfer pricing adjustments worth ₹105 crore related to sales, while remanding receivables interest for assessment year 2022-23 and excluding transfer pricing additions from minimum alternate tax. This decision provides critical relief for manufacturing enterprises facing inappropriate financial ratio benchmarks during audits.
Effective Assessment year 2022-23
For professionals: Advise manufacturing clients that the ITAT Jaipur ruling establishes that the Berry ratio is entirely inapplicable to businesses engaged in comprehensive manufacturing operations. · Inform clients that transfer pricing additions must be excluded from the computation of the minimum alternate tax. · Note that the issue of receivables interest was remanded back to the lower authorities for fresh consideration.
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