Transfer Pricing adjustment has to be confined to transactions with Associated Enterprises only

CA Suraj R. Agrawal Facts of the case: The Respondent is in the business of execution of turnkey contracts involving design, manufacture, supply, erection and commissioning of sugar plants, cement plants, etc. During the subject Assessment Year, the Respondent Assessee had International Transaction with its Associated Enterprises (AE) in respect of import of spares and equipments, royalty and project engineering, manufacturing drawings, settlement for liquidated damages and interest on delayed payments. The TPO on selection of comparables arrived at the margin at 6.29% as against 5.19% arrive...