https://www.taxtmi.com/caselaws?id=404901 The tribunal ruled that transfer pricing adjustments are limited to international transactions only, not entity-level transactions. It directed the adjustment to be restricted to international transactions, granting the assessee a hearing opportunity. Additionally, the tribunal required consistent treatment of VRS expenses in the operating cost base for the assessee and a comparable company, setting aside the order to include VRS costs for the comparable company in line with the assessee's treatment. The appeal was partly allowed based on these decisions, clarifying transfer pricing rules and expense treatment for operating profit margins. en-us Thu, 04 Mar 2021 00:00:00 +0530 Wed, 28 Jul 2021 18:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404901 The tribunal ruled that transfer pricing adjustments are limited to international transactions only, not entity-level transactions. It directed the adjustment to be restricted to international transactions, granting the assessee a hearing opportunity. Additionally, the tribunal required consistent treatment of VRS expenses in the operating cost base for the assessee and a comparable company, setting aside the order to include VRS costs for the comparable company in line with the assessee's treatment. The appeal was partly allowed based on these decisions, clarifying transfer pricing rules and expense treatment for operating profit margins. Case-Laws Income Tax Thu, 04 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404901