https://www.taxtmi.com/caselaws?id=754115 ITAT Hyderabad allowed the assessee's appeal for statistical purposes regarding transfer pricing adjustments. The TPO had computed adjustments on aggregate cost base including domestic operations costs, while the assessee argued that US-related transaction adjustments were resolved under MAP and domestic transaction adjustments with Indian entities were unjustified under Indian TP provisions. The tribunal held that ALP determination applies only to international transactions under Chapter X of the Income Tax Act. The matter was remanded to TPO for fresh examination to determine whether domestic services additions were legally sustainable, directing verification of whether adjustments regarding the domestic entity were warranted under law. en-us Wed, 27 Mar 2024 00:00:00 +0530 Tue, 18 Jun 2024 08:29:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754115 ITAT Hyderabad allowed the assessee's appeal for statistical purposes regarding transfer pricing adjustments. The TPO had computed adjustments on aggregate cost base including domestic operations costs, while the assessee argued that US-related transaction adjustments were resolved under MAP and domestic transaction adjustments with Indian entities were unjustified under Indian TP provisions. The tribunal held that ALP determination applies only to international transactions under Chapter X of the Income Tax Act. The matter was remanded to TPO for fresh examination to determine whether domestic services additions were legally sustainable, directing verification of whether adjustments regarding the domestic entity were warranted under law. Case-Laws Income Tax Wed, 27 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754115