ALP determinable on combined accounts approach in case of failure to separate common costs

Tasty Bite Eatables Limited Vs ACIT (ITAT Pune) Conclusion:  TPO determined ALP on the combined accounts approach rather than the split approach adopted by assessee as assessee failed to substantiate such common material costs were properly allocated segment-wise and Transfer Pricing Adjustment made at entity level should be restricted to international transactions only. Held: Assessee, who was engaged in the manufacture and sale of ready to eat foods, filed its return declaring total income of Rs.1,88,570, which was subsequently revised to the total income of Rs.9,38,410. It reported certain...