Restrict transfer pricing addition to international transactions under manufacturing activity segment: ITAT

Hyundai Construction Equipment India Private Ltd. Vs ACIT (ITAT Pune)

Ground no.8 of the appeal is against making transfer pricing adjustment on entity level rather than restricting it to the AE transactions. The TPO computed the transfer pricing addition by considering revenues from Manufacturing segment‘ in totality at the entity level The DRP did not concur with the assessee s submission that such issue was decided in favour of the assessee by the Hon‘ble Bombay High Court on the ground that the SLP filed by the Depar

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