TP Adjustments to be restricted to international transactions and cannot form the basis for rejecting books of accounts

Phoenix Mecano (India) Ltd Vs. DCIT (ITAT Mumbai) ITA No. 7646/Mum/2011, Date- 23.12.2011 Issues- 1. Whether adjustment should be restricted only to the international transactions or can be extended to the entire turnover of the taxpayer? 2. Are the books of accounts liable to be rejected if there is a transfer pricing adjustment? 3. Prior to 1.10.2009, is the benefit of standard deduction of-+5% under the proviso to section 92C(2) of the Act available to the taxpayer? Held –Placing reliance in the case of Star lite and various other decisions, the Tribunal held that the adjustments sho...