2019 (6) TMI 1529

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..... he revenue to challenge the judgment of the Income Tax Appellate Tribunal ("Tribunal" for short). Following questions were argued before us:- "(i) Whether on the facts and circumstances of the case and in law, the ITAT was correct in setting aside the adjustment made by the TPO in respect of import of raw material to the file of the TPO, for pro-rata adjustment considering only the AE transactio .....

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..... and the associated enterprise. The Transfer Pricing Officer ("TPO" for short) had made the adjustment to the entire segment of the manufacturing activity instead of making the adjustment for only international transaction. The Tribunal held that the TPO was not justified in making adjustment to the entire segment of manufacturing activity without restricting the same to the manufacturing transact .....

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