Rieter India (P) Ltd. v. Dy. CIT (2022) 215 TTJ 13 (UO) (Pune) Trib)

S. 92C : Transfer pricing-Arm’s length price-Restricted only to the international transactions-VRS expenses-Similar cost incurred by the comparables if any also be given. [S.37(1), 92CA]

Held that the  TP adjustment is to be restricted only to the international transactions rather than the entity level transactions. Tribunal also held that once the VRS expenses incurred by the assessee have been  included in its total operating costs, similar costs incurred by the comparables, if   any, should also be given a parallel treatment(AY. 2013-14)