Held that TP adjustments should be restricted to the AE transactions only. Reversal of provision for write back. Matter remanded. VAT refund is Non operating and vice versa. Miscellaneous income can not be considered as operating income. (AY. 2015-16)
Knorr Bremse Systems for Commercial Vehicles India (P) Ltd. v. Dy. CIT (2021) 198 DTR 196 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-TP adjustments should be restricted to the AE transactions only-Reversal of provision for write back-Matter remanded-VAT refund-Non operating and ice versa-Miscellaneous income-Can not be considered as operating income. [R. 10B]