Tribunal Supports Assessee: Removes Transfer Pricing Adjustment for Exports to AEs, Emphasizes Consistent Methodologies.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP adjustment - goods Exported to the Associated Enterprises (AE) - The Tribunal sided with the assessee, noting the principle of consistency should apply, as similar methodologies were accepted in previous years. They directed the deletion of the transfer pricing adjustment, emphasizing that the profitability of AEs in initial operational stages in new markets can justifiably be lower.....