TP Adjustment Restricted to AE Transactions Upheld – ITAT Bangalore Dismisses Revenue Appeal

DCIT Vs Brady Company India Private Limited (ITAT Bangalore) TP Adjustment Restricted to AE Transactions Upheld – ITAT Bangalore Dismisses Revenue Appeal In this case, the ITAT Bangalore upheld the CIT(A)’s direction that transfer pricing (TP) adjustments must be restricted only to international transactions with Associated Enterprises (AEs) and not applied to the entire turnover. The assessee, engaged in manufacturing, trading, and shared services, had a TP adjustment of ₹2.96 crore made by the TPO under TNMM. The CIT(A) directed multiple reliefs-restricting TP adjustment to AE transact...