ITAT Directs TP Reassessment And Holds Only AE Transactions Can Be Benchmarked for ALP Determination:
The Income Tax Appellate Tribunal (ITAT) Delhi has held that transfer pricing benchmarking should be restricted to international transactions with Associated Enterprises (AEs) and not the assessee's entire business operations where segmental profitability can be reasonably determined.
Transfer Pricing Analysis Must be Confined to International Transactions with Associated Enterprises
Saloni Kumari
Jun 4, 2026Premium
ITAT Directs TP Reassessment And Holds Only AE Transactions Can Be Benchmarked for ALP Determination
The Income Tax Appellate Tribunal (ITAT) Delhi has held that transfer pricing benchmarking should be restricted to international transactions with Associated Enterprises (AEs) and not the assessee's entire business operations where segmental profitability can be reasonably determined.
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Saloni Kumari
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Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
Saloni is a Content Writer with 2+ years of experience at studycafe.in. She writes legal, taxation, and finance related content including GST, Income Tax etc. Skilled in translating complex judicial pronouncements and regulatory developments into clear, and reader-friendly articles. Experienced in covering judgements of ITAT, High Court, GSTAT, and news related to Income Tax, GST, and corporate law. She can be reached at [email protected].
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