TP adjustments must be made on the basis of actual transactions with AE

IN THE ITAT MUMBAI BENCH ‘C’ Pennzoil Quaker State India Ltd. versus Deputy Commissioner of Income-tax, Range 1(2) IT Appeal No. 8885 (Mum.) of 2010 [Assessment year 2006-07] August 3, 2012 ORDER Rajendra Singh, Accountant Member This appeal by the assessee is directed against the order of AO dated 30.9.2010 passed in pursuance of direction under section 144C issued by The Dispute Resolution Panel-II. The assessee in this appeal has raised several grounds which relate to the transfer pricing adjustment made by AO as per direction of DRP, principle of natural justic...