Transfer-pricing benchmarking must separately assess support...

Transfer-pricing benchmarking must separately assess support services rendered on a cost-plus, limited-risk basis and subcontract receipts from a full-risk entrepreneurial segment where separate agreements, functional profiles and risks apply. Their common character as BPO services does not justify aggregation, particularly where separate audited accounts are furnished. The Tribunal rejected aggregation on those grounds. Applying the jurisdictional High Court ruling, the Tribunal also deleted notional interest on delayed receivables because the assessee was debt-free and the Revenue did not distinguish the precedent. The appeal was allowed.