Tara Jewels Exports Pvt Ltd - Bom HC
Bombay High Court dismisses Revenues appeal holding Transfer pricing adjustments can only be limited to transactions with Associated Enterprises (AE) and not on transactions with non-AE. [Tara Jewels Exports Pvt Ltd] Hence, where TNMM is used to determine ALP, the margin is only to be applied on sales/purchases with AE and not on the complete turnover of the assessee.
Posted on: 02-11-2015