Sec. 92C of income Tax Act, 1961—Transfer Pricing – Revenue preferred tax appeal against the order of ITAT in deleting transfer pricing adjustment. Tribunal noted that for earlier assessment years too there were no transfer pricing adjustments. Thus, there was no basis for concluding that assessee had provided any market support services to the AE or received any commission from the AE for providing such marketing support services. In the absence of concrete evidence, transfer pricing adjustment could not have been made merely on presumptions and surmises. Therefore, the transfer pricing adjustment was deleted. High Court dismissed the appeal of the revenue holding that the approach of the Tribunal is quite reasonable and pragmatic. - PR. CIT V/s SOLAR TURBINES INDIA (P.) LTD. - [2020] 272 TAXMAN 268 (BOM)