Transfer Pricing adjustment should be restricted to AE transactions: ITAT

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

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