Transfer pricing adjustments should target only international transactions with associated enterprises, not entire entities, per ESAS - ALP guidelines.

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....TP adjustment in Distribution activity, described as ESAS - ALP and the consequential transfer pricing adjustment are contemplated only in respect of the international transactions and not the entity level transactions. The TPO, in the instant case computed transfer pricing adjustment in respect of entity level transactions. We direct to restrict it to the AE transactions under consideration and not the entity level transactions. - AT....