https://www.taxtmi.com/caselaws?id=210111 ITAT, MUMBAI upheld a transfer-pricing adjustment in part: it rejected the assessee's aggregation of application research, technology licensing and technical development, finding application research at the BRDTC conferred benefit solely to the A.E. and warranted adjustment for absence of markup. The Tribunal held prior-year data cannot be used unless the assessee specifically demonstrates relevance. It upheld rejection of two comparables as flawed for functional and abnormality reasons. No additional risk or working-capital adjustment was granted, and the ALP for back-office support services was accepted as within the comparable range. en-us Fri, 10 Jun 2011 00:00:00 +0530 Fri, 22 Aug 2025 10:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210111 ITAT, MUMBAI upheld a transfer-pricing adjustment in part: it rejected the assessee's aggregation of application research, technology licensing and technical development, finding application research at the BRDTC conferred benefit solely to the A.E. and warranted adjustment for absence of markup. The Tribunal held prior-year data cannot be used unless the assessee specifically demonstrates relevance. It upheld rejection of two comparables as flawed for functional and abnormality reasons. No additional risk or working-capital adjustment was granted, and the ALP for back-office support services was accepted as within the comparable range. Case-Laws Income Tax Fri, 10 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210111