https://www.taxtmi.com/caselaws?id=242675 In transfer pricing of purchases from associated enterprises, the arm's length price must be computed only with reference to the international transactions with those enterprises, not on the assessee's entire turnover. The absence of separate accounts for controlled and uncontrolled transactions does not, by itself, justify applying a net profit margin to local or other non-AE transactions. The adjustment must remain confined to purchases from associated enterprises, with any fresh computation to be made on that restricted basis. en-us Fri, 28 Jun 2013 00:00:00 +0530 Sun, 19 Jan 2014 09:47:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242675 In transfer pricing of purchases from associated enterprises, the arm's length price must be computed only with reference to the international transactions with those enterprises, not on the assessee's entire turnover. The absence of separate accounts for controlled and uncontrolled transactions does not, by itself, justify applying a net profit margin to local or other non-AE transactions. The adjustment must remain confined to purchases from associated enterprises, with any fresh computation to be made on that restricted basis. Case-Laws Income Tax Fri, 28 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242675