https://www.taxtmi.com/caselaws?id=189176 The High Court upheld the Tribunal's decision to limit Arm's Length Price (ALP) adjustments to international transactions with Associated Enterprises (A.E.) only, rejecting the Revenue's argument for broader application. The Court found the Tribunal's direction to consider ALP adjustments solely for international transactions with A.E. to be correct. The issue of excluding gains on foreign exchange fluctuation from Operating Profit/Operating Costs (OP/OC) was referred for further analysis by the High Court. The judgment emphasized adherence to legal precedents and principles in transfer pricing disputes. en-us Mon, 11 Jan 2016 00:00:00 +0530 Fri, 30 Dec 2016 12:33:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189176 The High Court upheld the Tribunal's decision to limit Arm's Length Price (ALP) adjustments to international transactions with Associated Enterprises (A.E.) only, rejecting the Revenue's argument for broader application. The Court found the Tribunal's direction to consider ALP adjustments solely for international transactions with A.E. to be correct. The issue of excluding gains on foreign exchange fluctuation from Operating Profit/Operating Costs (OP/OC) was referred for further analysis by the High Court. The judgment emphasized adherence to legal precedents and principles in transfer pricing disputes. Case-Laws Income Tax Mon, 11 Jan 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189176