In transfer pricing proceedings, TPO made adjustment to entire segment of manufacturing activity instead of making adjustment for only international transaction. ITAT held that TPO was not justified in making adjustment to entire segment of manufacturing activity and remanded matter back to TPO to verify and decide value of adjustment by taking appropriate revised margin rate. (AY. 2008-09 2009-10)
Bunge India Pvt. Ltd. v. Add CIT (2021) 87 ITR 34 (SN.) (Mum.)(Trib.)
S. 92C : Transfer pricing-Arms’ length price-Pro-rata adjustment considering only associated enterprises.