Only international and not entity level transactions covered in transfer pricing adjustment

Huntsman International (India) Pvt Ltd Vs DCIT (ITAT Ahmedabad) ITAT Ahmedabad held that transfer pricing adjustment should be restricted only in respect of turnover of assessee-company relating to international transactions. In nut-shell, transfer pricing addition should be restricted only qua international transaction and not entity level transactions. Facts- The issue for consideration here is that whether the transfer pricing adjustment should be restricted to international transactions by the assessee with its associated enterprise or whether the adjustment is required to be computed at e...