2015 (4) TMI 1107

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..... case and in law, the Hon'ble ITAT is justified in holding that the Transfer Pricing Officer ought to have confined himself to transfer pricing adjustments to the international AE transactions only, instead at entity level, without appreciating that the assessee had not furnished segmental audited accounts before the Transfer Pricing Officer ? (2) Whether on the facts and circumstances of the case .....

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..... the purchase transactions and had worked out the adjustment on purchases. Therefore despite the transactions being not at arm's length, the assessee has got away without any adjustment.?”
S.C. DHARMADHIKARI & A.K. MENON, JJ. Mr. Arvind Pinto for the Appellant Mr. for the Respondent JUDGEMENT 1. Having heard Mr. Pinto and perusing the order of the Tribunal, we find that the appeal deserve .....

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..... transactions on the basis of overall margins and (b) the presumption underlying arm's length principle is that uncontrolled transactions are at arm's length, and therefore, if the overall margins are less than arm's length margins, the short fall must be on account of AE transactions only and not on pro rata basis ? (3) Whether on the facts and circumstances of the case and in law, .....

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