Tribunal held that no transfer pricing adjustment can be made on transactions with the non-AEs is supported by the judgment of the Hon’ble Delhi High Court in CIT v. Keihin Panalfa Ltd. (2016) 381 ITR 407 (Del), in which it has been held that the transfer pricing adjustment can be made only with reference to the international transactions and not the transactions with the non-associated enterprises. Similar view has been espoused by the Hon’ble Bombay High Court in CIT vs. Thyssen Krupp Industries India Private Ltd. (2016) 381 ITR 413  (Bom.)(HC) Matter remanded to the file of the TPO/AO.(AY. 2010-11)