No ALP adjustment where buyer outsourced purchase only for administrative convenience & seller is only charging fixed manufacturing charges

Brief of the Case Delhi High Court held In the case of Johnson Matthey India Pvt. Ltd. vs. DCIT that the purpose of transfer pricing is to benchmark transactions between related parties in order to discover the true price if such entities were unrelated. If Maruti Udyog Ltd. (MUL) had bought the goods directly from party named JMUK there would have been no application of transfer pricing since MUL and JMUK are unrelated entities. MUL would have purchased the goods just like JMIPL did on negotiated prices. There is merit in the contention that the prices at which JMIPL purchased PGM from JMUK w...