TP Adjustment should be restricted to AEs Transactions

Toyota Kirloskar Motor (P) Ltd Vs ACIT (ITAT Bangalore)

The Appellant submits the in its own case for AY 2003-04, the Honourable Bangalore Tribunal has accepted that TP adjustment has to restricted to AE transactions. Further, in Appellants own case for AY 2013-14 [ITA No.2016/Bang/2018, dated 18.08.2021], the Honourable Bangalore Tribunal has upheld the action of CIT(A) in directing the TPO to restrict TP adjustment to AE transactions.

A similar issue has been decided by us in assessee’s own case for the assessment

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