Sections 92, 92B, 92C of Income Tax Act, 1961—Transfer Pricing—  Hyundai Rotem Company is a South Korean Company and is a part of Hyundai Motor Group and it is engaged in producing all kinds of railway vehicles, such as electric multiple unit, high speed trains, light rail vehicles, locomotives and passenger coaches, car manufacturing systems and environment plants. It provides rail business solutions throughout the world, ranging from manufacture of rolling stock to the supply of turnkey rail systems. Its business scope includes not only advanced defence industry products but also production and supply of industrial plants and environment friendly facilities. The Rotem has set up project offices in India. Assessee filed an appeal against the final assessment order passed u/s 143(3). 
Court direct the TPO to examine the assessee’s quantification of risk adjustment specifically where assessee has taken the difference between bank rates and SBI bank rate and the quantification done by the assessee of the risk adjustment on 10.50%, is correct or not. With this direction this issue was remanded back to the TPO/Assessing Officer.
In view of the findings, the other grounds were not adjudicated. Accordingly, the appeal of the assessee was treated as allowed. The appeal of the assessee was allowed. --- HYUNDAI ROTEM COMPANY vs. Asstt. CIT[2020] 23 ITCD Online 62 (DEL)