ALP Adjustment of International Transaction Restricted to AEs

Terex India (P) Ltd. Vs DCIT (ITAT Pune) CONCLUSION – Adjustment on account of arm’s length price (ALP) of international transaction is restricted only to the extent of international transaction with associated enterprises (AE). FACTS – Assessee is engaged in manufacturing of material handling equipment and has entered into various international transactions with its associated enterprises. Reference was made to Transfer Pricing Officer (TPO) for determination of the arm’s length price of the transaction reported in Form 3-CEB. Assessee applied Transactional Net Margin Method and sele...