Transfer pricing adjustment should be restricted to AE transactions only: SC Admits SLP

CA Reetika Agarwal CIT v Firestone International Private Limited [TS-806-SC-2016] Hon’ble Supreme Court admits the SLP- Transfer pricing adjustment should be restricted to AE transactions only and not on the entire turnover of the assessee. Facts 1. The assessee was engaged in the business of export of diamond and also manufacturing of jewellery. The assesse has two units: Diamond Polishing and manufacturing of Jewellery. The unit manufacturing jewellery is claiming deduction u/s 10B of the Incoma Tax Act, 1961 (“The Act”). The assessee adopted the TNM method at entity level and consid...