https://www.taxtmi.com/caselaws?id=757417 Transfer pricing adjustment under Chapter X of the Income-tax Act, 1961 must be confined to international transactions with associated enterprises. A computation that aggregates non-AE revenue and non-AE costs in the software development segment is inconsistent with the statutory scheme and with remand directions requiring verification of the adjustment. The adjustment therefore had to be recomputed on an AE-only basis, excluding domestic or other non-AE items. The tax computation was directed to be revised accordingly, and the matter was disposed of for statistical purposes. en-us Wed, 21 Aug 2024 00:00:00 +0530 Sat, 24 Aug 2024 09:05:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757417 Transfer pricing adjustment under Chapter X of the Income-tax Act, 1961 must be confined to international transactions with associated enterprises. A computation that aggregates non-AE revenue and non-AE costs in the software development segment is inconsistent with the statutory scheme and with remand directions requiring verification of the adjustment. The adjustment therefore had to be recomputed on an AE-only basis, excluding domestic or other non-AE items. The tax computation was directed to be revised accordingly, and the matter was disposed of for statistical purposes. Case-Laws Income Tax Wed, 21 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757417