Transfer Pricing adjustment has to be done only in respect of International Transactions with Associated Enterprises

While dealing with transfer pricing adjustment in the absence of segmental accounts held that adjustments have to be restricted only to transactions with Associated Enterprises. It further held that where separate accounts are not available, then proportionate adjustments to be made only in respect of the international transactions with Associated Enterprises. Relevant Extract of the Judgment 3. The impugned order of the Tribunal upheld the Respondent assessee’s contention that the transfer pricing adjustment has to be made only in respect of transaction entered into by the Respondent as...