Transfer pricing study selecting AE as tested party duly acceptable: ITAT Mumbai

ACIT (LTU-1) Vs Glenmark Pharmaceuticals Ltd (ITAT Mumbai) ITAT Mumbai held that assessee selecting Associated Enterprise (AE) as “tested party” justifiable. Accordingly, transfer pricing study conducted by the assessee is duly acceptable. Facts- The assessee had entered international transactions in the nature of export of goods (formulations) to its Associated Enterprises located in 12 Countries. Besides it had exported R & D services to Switzerland, imported formulations from Argentina. In the Transfer pricing study, the assessee had selected AEs as ‘Tested party” and TNM method...