https://www.taxtmi.com/caselaws?id=460406 The ITAT Chennai held that overseas entities could not be treated as deemed Associated Enterprises under section 92A, finding that "influence" requires dominant control rather than mere influence, and that small export sales to these entities did not establish such dominance. The tribunal allowed the assessee's appeal on this issue. Regarding transfer pricing adjustments under section 92CA(3), the ITAT directed the TPO to recompute arm's length price by aggregating all transactions with AEs rather than examining individual transactions, following OECD guidelines and precedent requiring consideration of both higher and lower margin transactions for holistic assessment. The appeals were partly allowed. en-us Fri, 27 Sep 2024 00:00:00 +0530 Wed, 22 Jan 2025 18:57:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460406 The ITAT Chennai held that overseas entities could not be treated as deemed Associated Enterprises under section 92A, finding that "influence" requires dominant control rather than mere influence, and that small export sales to these entities did not establish such dominance. The tribunal allowed the assessee's appeal on this issue. Regarding transfer pricing adjustments under section 92CA(3), the ITAT directed the TPO to recompute arm's length price by aggregating all transactions with AEs rather than examining individual transactions, following OECD guidelines and precedent requiring consideration of both higher and lower margin transactions for holistic assessment. The appeals were partly allowed. Case-Laws Income Tax Fri, 27 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460406