Held that transfer pricing adjustment ought to have been restricted to international transactions with Associated Enterprises rather than entity level transactions. (AY. 2015-16)
Minda Rinder (P.) Ltd. v. ACIT (2021) 188 ITD 513 / 210 TTJ 545 / 200 DTR 58 / 86 ITR 25 (SN) (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Restricted to international transactions with Associated Enterprises.