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The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP adjustment on the total cost base, including domestic operations, despite resolution of US-related adjustments through Mutual Agreement Procedure. The question was whether domestic operations fall u/s Indian TP provisions. ITAT held that TP should be determined for international transactions u/s Chapter X of Income Tax Act, and domestic TP adjustments must comply with law. The matter was remanded to Assessing Officer/TPO for reassessment of domestic TP adjustments to ensure compliance with law. The appeal was allowed for statistical purposes.
The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP adjustment on the total cost base, including domestic operations, despite resolution of US-related adjustments through Mutual Agreement Procedure. The question was whether domestic operations fall u/s Indian TP provisions. ITAT held that TP should be determined for international transactions u/s Chapter X of Income Tax Act, and domestic TP adjustments must comply with law. The matter was remanded to Assessing Officer/TPO for reassessment of domestic TP adjustments to ensure compliance with law. The appeal was allowed for statistical purposes.
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