Mtu India (P) Ltd. v. DCIT (2021) 211 TTJ 978 / 203 DTR 390 (Pune)(Trib.)

S. 92C : Transfer pricing-Arm’s length price-Operating revenue expenses incurred-Order set aside-TP adjustment are only in respect of international transactions and not entry level transactions. [S. 92]

Tribunal held that when an international transactions is concluded in the  succeeding year the costa/ revenue of the said transaction from first year also qualify for consideration in determining ALP even though characterized   as prior period costs / revenue. Matter set aside for decide a fresh.  Tribunal also held that TP adjustment are only in respect of international transactions and not entry level transactions.   (AY.  2013-14)