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of The ITAT upheld the transfer pricing adjustment under Chapter X of the Income Tax Act, confirming that the foreign enterprise and its Indian PE constitute associated enterprises under Section 92A(2)(g). The PE was held to be a fixed place of business through which the HO's business is conducted, with no separation of capital or control. The Tribunal rejected the assessee's contention that the onshore agreement could be used as a comparable under the CUP method, finding it not at arm's length due to inadequate compensation. The presence of multiple persons and offices in India as PEs of the foreign enterprise was affirmed. The Tribunal upheld the TPO's determination of the ALP using the most appropriate method (TNMM), resulting in a transfer pricing adjustment of Rs. 22 Crores for offshore contract activities. The assessee's arguments challenging the PE status and adjustment were dismissed.
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