AE Transactions Must Be Benchmarked Separately When Segmental Data Exists: ITAT Delhi

Cornell Overseas Pvt Ltd Vs DCIT (ITAT Delhi) The case concerns transfer pricing adjustments for Assessment Year 2007-08 involving a company engaged in the manufacture and export of readymade garments for ladies and children, as well as home furnishings. The appeal challenged the assessment order passed under Sections 254/143(3) read with Section 144C of the Income Tax Act pursuant to the directions of the Dispute Resolution Panel (DRP). The assessee was a 100% Export Oriented Undertaking, with approximately 96% of its turnover arising from exports and the remaining 4% from local sales such as...