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Transfer Pricing adjustment should be restricted to AE transactions: ITAT
Case Law Details
- Case Name
- Tokai Rika Minda India Private Limited Vs DCIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-2013
- Courts
- All ITAT, ITAT Bangalore
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Tokai Rika Minda India Private Limited Vs DCIT (ITAT Bangalore)
On the issue of Transfer Pricing (TP) adjustment to be restricted to AE transactions, we find that the Assessee has rightly contended that section 92 of the Act can be applied only in respect of international transactions i.e., transactions with AE. The ITAT in the case of Continental Automotive Components India Private Limited IT(TP)A No713/Bang/2017 has held as follows:
“53. We have considered the rival submissions. This issue was considered by the Hon’ble Supreme Court in the case of CITv. Hindustan Unilever Ltd., 99 ta...
