Transfer Pricing adjustment cannot be made in respect of transactions with unrelated third parties

Issue Before Court

Whether on the facts and the circumstance of the case and law, the Tribunal was justified in law in restricting the Transfer   Pricing   (TP)   adjustment   only   to   the   transaction between the Associated Enterprises (AEs.)?

Facts of the Case

(a) 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

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