section 271(1) (c ) of the Act, which are premature in nature, hence do not require adjudication. 6. Now we shall take first common issue of these two appeals, which relates to whether the foreign associated enterprises (AE) can be considered as a tested party as per Indian Transfer Pricing Regulation? Almatis Alumina Pvt. Ltd. ITA Nos.726&2361/Kol/2017 Assessment Years