TP adjustment restricted to international transaction with AE as segmental accounts not maintained

Thermo Fisher Scientific India Pvt. Ltd. Vs DCIT (ITAT Mumbai)

ITAT Mumbai held that where segmental accounts are not available, then proportionate adjustments have to be made only in respect of the international transactions with associated enterprises [AE]. Thus, TPO directed to compute the transfer pricing [TP] adjustment, restricting it to the international transactions undertaken with associated enterprises.

Facts- The assessee has filed the present appeals against the separate final assessment order passed under section 143(3) read with section 144C(

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