https://www.taxtmi.com/caselaws?id=336763 Transfer pricing adjustment under Chapter X must be confined to international transactions with associated enterprises and cannot be made at the entity level merely because segmental accounts are unavailable. The absence of segmental accounting does not justify bringing non-associated enterprise transactions within the adjustment mechanism, because a proportionate basis can be adopted to isolate the relevant AE transactions. The Court also noted the need for consistency with an earlier similar position accepted by the revenue. The adjustment was therefore restricted to transactions with associated enterprises. en-us Wed, 14 Sep 2016 00:00:00 +0530 Sat, 17 Jun 2017 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336763 Transfer pricing adjustment under Chapter X must be confined to international transactions with associated enterprises and cannot be made at the entity level merely because segmental accounts are unavailable. The absence of segmental accounting does not justify bringing non-associated enterprise transactions within the adjustment mechanism, because a proportionate basis can be adopted to isolate the relevant AE transactions. The Court also noted the need for consistency with an earlier similar position accepted by the revenue. The adjustment was therefore restricted to transactions with associated enterprises. Case-Laws Income Tax Wed, 14 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336763