https://www.taxtmi.com/caselaws?id=284566 The Tribunal upheld the rejection of Foreign/Associated Enterprises (AEs) as the tested party for transfer pricing analysis, emphasizing the comparison of profit margins with Indian enterprises. It directed reconsideration of depreciation adjustments, requiring evidence of differing rates. The restriction of transfer pricing adjustments solely to international transactions was affirmed, and the deletion of a transfer pricing addition using the Resale Price Method (RPM) was approved, with directions for reassessment. Both appeals were partly allowed for statistical purposes, ensuring adherence to legal standards. en-us Wed, 24 Apr 2019 00:00:00 +0530 Tue, 26 Nov 2019 12:51:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284566 The Tribunal upheld the rejection of Foreign/Associated Enterprises (AEs) as the tested party for transfer pricing analysis, emphasizing the comparison of profit margins with Indian enterprises. It directed reconsideration of depreciation adjustments, requiring evidence of differing rates. The restriction of transfer pricing adjustments solely to international transactions was affirmed, and the deletion of a transfer pricing addition using the Resale Price Method (RPM) was approved, with directions for reassessment. Both appeals were partly allowed for statistical purposes, ensuring adherence to legal standards. Case-Laws Income Tax Wed, 24 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=284566