https://www.taxtmi.com/caselaws?id=460854 The ITAT Mumbai held that transfer pricing adjustments must be restricted to international transactions with associated enterprises only, not at entity level which includes non-AE transactions. Following Tara Jewels Exports precedent, the tribunal directed the TPO to recompute arm's length price considering only AE transactions, as entity-level adjustments would create absurdity where total international transaction value would be less than the adjustment made. Additionally, the tribunal directed the AO to verify and grant appropriate TDS credit after factual verification. en-us Tue, 08 Jan 2019 00:00:00 +0530 Tue, 25 Feb 2025 19:16:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460854 The ITAT Mumbai held that transfer pricing adjustments must be restricted to international transactions with associated enterprises only, not at entity level which includes non-AE transactions. Following Tara Jewels Exports precedent, the tribunal directed the TPO to recompute arm's length price considering only AE transactions, as entity-level adjustments would create absurdity where total international transaction value would be less than the adjustment made. Additionally, the tribunal directed the AO to verify and grant appropriate TDS credit after factual verification. Case-Laws Income Tax Tue, 08 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460854