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, fi

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