PCIT v. Bunge India (P.) Ltd. (2019) 265 Taxman 207 (Bom.)(HC)

S. 92C : Transfer pricing–Pro-rata adjustment considering only associated enterprises-Matter remanded-No question of law. [S. 260A]

In transfer pricing proceedings, TPO made adjustment to entire segment of manufacturing activity instead of making adjustment for only international transaction. Tribunal held that TPO was not justified in making adjustment to entire segment of manufacturing activity and remanded matter back to TPO in respect of import of raw material for pro-rata adjustment considering only Associated Enterprise   transactions. No substantial question of law.