https://www.taxtmi.com/caselaws?id=358272 Under the Transactional Net Margin Method, transfer pricing benchmarking must be confined to international transactions with associated enterprises, and Chapter X does not permit an adjustment based on the assessee's total entity-level costs or on transactions with non-associated enterprises. The computation using costs relatable to non-AE transactions was therefore legally unsustainable. The matter was remanded to the Assessing Officer/Transfer Pricing Officer for fresh consideration in accordance with law, with the transfer pricing addition set aside to that extent and benchmarking restricted to international transactions alone. en-us Tue, 13 Mar 2018 00:00:00 +0530 Mon, 09 Apr 2018 08:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358272 Under the Transactional Net Margin Method, transfer pricing benchmarking must be confined to international transactions with associated enterprises, and Chapter X does not permit an adjustment based on the assessee's total entity-level costs or on transactions with non-associated enterprises. The computation using costs relatable to non-AE transactions was therefore legally unsustainable. The matter was remanded to the Assessing Officer/Transfer Pricing Officer for fresh consideration in accordance with law, with the transfer pricing addition set aside to that extent and benchmarking restricted to international transactions alone. Case-Laws Income Tax Tue, 13 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358272