ACIT v. United Shippers Ltd. (2022) 97 ITR 94 (Mum) (Trib)

S. 92C : Transfer pricing-Arm’s length price-Profit margin to be applied only on international transactions. [S.92CA]

The Tribunal held that CIT (A) erred in applying profit level indicator on assessee’s total sale instead of applying only to international transactions. Therefore, the profit margin had to be applied only on international transaction. (AY. 2007-08)