The Tribunal held that the transfer pricing adjustment cannot extend to non-AE transactions. The matter is remitted to the file of AO/TPO for restricting the transfer pricing adjustment only in respect of the AE transactions. (AY. 2015-16)
Knorr Bremse Systems for Commercial Vehicles India (P.) Ltd v. DCIT (2021) 209 TTJ 1035 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Transfer Pricing adjustment cannot extend to non-AE transactions and to that extent a proportionate adjustment is warranted.