As Internat'nl transact'ns consistent with ALP, thus no TP adjustments, ITAT
Dec. 11, 2015
Assessee, subsidiary of foreign Co. mfd. & traded fluid power hydraulic equipm't. It imported raw materials & exported finished goods. TPO held, separate benchmarking required to be undertaken for manufacturing as well as trading segment. Thus, an adjustment was computed by applying external TNMM. On appeal ITAT held, international transactions entered into were consistent with ALP & no transfer pricing adjustment was required to be mad…