https://www.taxtmi.com/caselaws?id=269772 Transfer pricing adjustment under Chapter X of the Income-tax Act, 1961 is confined to international transactions with associated enterprises, where arm's length price must be determined to prevent profit shifting. Transactions with independent third parties do not fall within that adjustment mechanism because they are outside the scope of AE dealings and do not raise the same tax-avoidance concern. Extending transfer pricing rules to non-AE transactions would enlarge income computation beyond Chapter X. The Bombay High Court accordingly held that the adjustment cannot be applied to transactions with unrelated parties. en-us Wed, 02 Dec 2015 00:00:00 +0530 Sat, 24 Jan 2026 11:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=269772 Transfer pricing adjustment under Chapter X of the Income-tax Act, 1961 is confined to international transactions with associated enterprises, where arm's length price must be determined to prevent profit shifting. Transactions with independent third parties do not fall within that adjustment mechanism because they are outside the scope of AE dealings and do not raise the same tax-avoidance concern. Extending transfer pricing rules to non-AE transactions would enlarge income computation beyond Chapter X. The Bombay High Court accordingly held that the adjustment cannot be applied to transactions with unrelated parties. Case-Laws Income Tax Wed, 02 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=269772