Transfer pricing adjustment can be made only to the international transactions

Court – Delhi Tribunal

Citation: Abhishek Auto Industries Vs. DCIT (2010- TII-54-ITAT-DEL-TP)

Brief :Payment of royalty and know how fee under an agreement can not be ignored by the Revenue while doing the Transfer Pricing analysis, the transfer pricing adjustment can be made only to the international transactions and not transactions at the enterprise level which include domestic transactions, and internal comparability is most effic

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