https://www.taxtmi.com/caselaws?id=763047 ITAT Mumbai ruled that when TNMM is applied as the Most Appropriate Method for transfer pricing adjustments, the adjustment should be restricted to international transactions only, not applied at the entity level across the entire manufacturing segment. The Tribunal followed HC precedents establishing that TPO cannot make adjustments to the complete manufacturing activity segment. Additionally, the assessee was granted the benefit of the +/-5% tolerance range under Section 92C(2) proviso. After applying this tolerance range, no adjustment remained, confirming the transaction was at arm's length. The assessee's appeal was allowed. en-us Wed, 08 May 2024 00:00:00 +0530 Wed, 11 Dec 2024 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763047 ITAT Mumbai ruled that when TNMM is applied as the Most Appropriate Method for transfer pricing adjustments, the adjustment should be restricted to international transactions only, not applied at the entity level across the entire manufacturing segment. The Tribunal followed HC precedents establishing that TPO cannot make adjustments to the complete manufacturing activity segment. Additionally, the assessee was granted the benefit of the +/-5% tolerance range under Section 92C(2) proviso. After applying this tolerance range, no adjustment remained, confirming the transaction was at arm's length. The assessee's appeal was allowed. Case-Laws Income Tax Wed, 08 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763047