Transactions among Indian subsidiaries pursuant to contract with their parent cos. out of purview of

IT/ILT : Where assessee sold its medical imaging business to another Indian Company namely 'C' Ltd. in pursuance of larger transaction whereby holding company of assessee sold its imaging business to holding company of 'C' on global basis, since both transactions were independent of each other and there was no international element involved in assessee's transaction, revenue authorities were not justified in making transfer pricing adjustment to transaction entered into by assessee