ALP scope Restricted

This ruling reinforces a now-settled but frequently litigated principle:

ALP adjustments operate transaction-specifically not entity wide.

The Tribunal rejected the Revenue’s attempt to apply TNMM adjustments across the entire manufacturing segment, emphasizing that only AE transactions fall within Chapter X.

It also confirms that once adjustments (capacity, working capital, etc.) are verified and accepted by TPO, Revenue cannot reopen them mechanically.