Korean firm's international transactions with non-Korean affiliates require re-evaluation of transfer pricing adjustment.

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....The ITAT allowed the assessee's appeal for statistical purposes. It set aside the adjustment made by the TPO regarding the assessee's international transactions with non-Korean Associated Enterprises (AEs) not covered by the Mutual Agreement Procedure (MAP) resolution. The matter was restored to the TPO to consider whether these transactions were similar in nature to those with Korean AEs covered by the MAP resolution. If found similar, the TPO may apply the same treatment adopted under the MAP resolution. The TPO must provide the assessee a proper opportunity and pass an order in accordance with the law on this limited issue.....