Allowing the appeal the Tribunal held that, Transfer pricing adjustment to be restricted to International Transactions rather than entity level transactions in conformity with the Tribunal’s observations. (AY. 2015-16)
Minda Rinder P. Ltd. v. ACIT (2021)86 ITR 25 (SN) (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Transfer pricing adjustment to be restricted to International Transactions rather than entity level transactions. [S. 92(1)]