Transfer pricing disputes over intra-group services, the sensor...

Transfer pricing disputes over intra-group services, the sensor assembling segment and business support services were restored for fresh adjudication because the assessee sought to place additional evidence and the Tribunal found reconsideration necessary. The intra-group services adjustment was remitted to the AO/TPO for fresh decision after due opportunity. The choice between the Resale Price Method and the Transactional Net Margin Method for the sensor assembling segment was left open for reconsideration, and the comparables, filter changes and denied risk adjustment in business support services were also remitted. The assessment order was set aside to that extent and the appeal was partly allowed for statistical purposes.

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