Transfer pricing adjustment can be made only to the international transactions

Court – Delhi Tribunal Citation: Abhishek Auto Industries Vs. DCIT (2010- TII-54-ITAT-DEL-TP) Brief :Payment of royalty and know how fee under an agreement can not be ignored by the Revenue while doing the Transfer Pricing analysis, the transfer pricing adjustment can be made only to the international transactions and not transactions at the enterprise level which include domestic transactions, and internal comparability is most efficient when it involves the transactions of the tested party itself. Facts: Abhishek Auto Industries (assessee) was engaged in manufacturing of car seat bel...