TP adjustment - consideration paid to the associated enterprise...

TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the assessee (i.e. step down subsidiary of the associated enterprise) - The tribunal upheld the transfer pricing adjustments made by the tax authorities, distinguishing the nature of the transaction as an international transaction subject to transfer pricing provisions, despite the merger's approval by regulatory bodies. - The ruling emphasized that transactions, even if approved by regulatory bodies, must still be assessed for arm's length compliance within the framework of transfer pricing laws.