https://www.taxtmi.com/caselaws?id=435799 Transfer pricing adjustment must be confined to international transactions with Associated Enterprises and cannot be extended to the entity's entire turnover. The ITAT also upheld rejection of the Comparable Uncontrolled Price method because controlled transactions with Associated Enterprises are not uncontrolled comparables, and sustained adoption of the Transactional Net Margin Method as the most appropriate method on the facts. It further held that a higher-turnover comparable need not be excluded absent evidence of functional or economic distortion, and that a company with incomplete financial data could properly be rejected from the comparables set. en-us Mon, 12 Dec 2022 00:00:00 +0530 Mon, 27 Mar 2023 17:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435799 Transfer pricing adjustment must be confined to international transactions with Associated Enterprises and cannot be extended to the entity's entire turnover. The ITAT also upheld rejection of the Comparable Uncontrolled Price method because controlled transactions with Associated Enterprises are not uncontrolled comparables, and sustained adoption of the Transactional Net Margin Method as the most appropriate method on the facts. It further held that a higher-turnover comparable need not be excluded absent evidence of functional or economic distortion, and that a company with incomplete financial data could properly be rejected from the comparables set. Case-Laws Income Tax Mon, 12 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435799