Held that net margin method adjustments to be restricted to international transactions and not to be applied to entire segment of manufacturing activity. Assesee is entitled to benefit of tolerance range of +5 Per Cent.(AY. 2008-09, 2009-10)
Add.CIT v. Bunge India Pvt. Ltd. (2021) 87 ITR 34 (SN) (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Net margin method-Adjustments to be restricted to international transactions and not to be applied to entire segment of manufacturing activity-Entitled to benefit of tolerance range of +5 Per Cent. [S. 92CA]