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TMI Blog2016 (12) TMI 1822X X X X Extracts X X X X X X X X Extracts X X X X ..... :- Transfer Pricing Adjustment has to be done only in respect of the transaction entered into with the Associated Enterprises and not in respect of all transactions of the entity. See The Commissioner of Income Tax1, Mumbai v/s. Hindustan Unilever Ltd. [ 2016 (7) TMI 1245 - BOMBAY HIGH COURT] AND CIT v/s. Alstom Projects India Ltd [ 2016 (12) TMI 1408 - BOMBAY HIGH COURT ] Delhi High Court has als ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Transactions where the assessee has selected TNMM and applied the same on entity level because presumption underlying Arms Length Principle is that uncontrolled transactions are at Arm's Length and therefore if the overall margins are less than Arms Length Margins, the short fall must be on account of AE transactions only and not on pro rata basis?". 3 It is an agreed position between the par ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ases, this Court has held that the transfer Pricing Adjustment has to be done only in respect of the transaction entered into with the Associated Enterprises and not in respect of all transactions of the entity. Further, the Delhi High Court has also in CIT v/s. Keihin Panalfa Ltd., (ITA No.11 of 2015 decided on 9th September, 2015) has also independently taken the same view. 4 The learned Couns ..... X X X X Extracts X X X X X X X X Extracts X X X X
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