https://www.taxtmi.com/caselaws?id=439866 The Court upheld the ITAT's decision that Transfer Pricing (TP) adjustments should be proportionate to the value of international transactions, aligning with the arm's length principle applied only to associated enterprises (AE) transactions. It rejected the idea of benchmarking against the entire turnover, following precedents like Commissioner of Income Tax Vs. Alstom Projects India Ltd. The Court also dismissed the Revenue's appeal, noting that the issue of disallowance under Section 14A was not relevant to TP adjustments in the current case. The appeal was dismissed, reinforcing the decision in Hindustan Unilever Ltd. en-us Wed, 28 Jun 2023 00:00:00 +0530 Mon, 30 Oct 2023 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439866 The Court upheld the ITAT's decision that Transfer Pricing (TP) adjustments should be proportionate to the value of international transactions, aligning with the arm's length principle applied only to associated enterprises (AE) transactions. It rejected the idea of benchmarking against the entire turnover, following precedents like Commissioner of Income Tax Vs. Alstom Projects India Ltd. The Court also dismissed the Revenue's appeal, noting that the issue of disallowance under Section 14A was not relevant to TP adjustments in the current case. The appeal was dismissed, reinforcing the decision in Hindustan Unilever Ltd. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439866