Transfer Pricing – Segmental accounts of assessee required to be considered for determination of assesses profit to total cost from international transaction

Addition of Rs.19.14 crore has been made on the basis of the assessee’s operating margin from its total operations within and outside India arising due to both the controlled and uncontrolled transactions with the associated enterprises and nonassociated enterprises. The addition on account of transfer pricing adjustment can be made by comparing the assessee’s result from the international transactions with the AEs with those from comparable uncontrolled transactions of outside parties. Under the TNMM, the process is simple to initially find out the average of the operating profit margin o...