https://www.taxtmi.com/caselaws?id=249439 The High Court upheld the decision of the Income Tax Appellate Tribunal (ITAT) in a transfer pricing adjustment case. The appellant, a subsidiary of a Japanese company, argued its functional profile was that of a service provider, not a trader. However, the ITAT determined the appellant's activities resembled trading, not that of a commission agent or broker, emphasizing transactions on a principal-to-principal basis. The Court affirmed this assessment, highlighting the need for comparables reflecting the appellant's functional profile, risk exposure, and working capital in determining the Arm's Length Price (ALP). The appeal was dismissed, providing clarity on selecting comparables for ALP determination. en-us Fri, 04 Jul 2014 00:00:00 +0530 Tue, 17 Feb 2015 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249439 The High Court upheld the decision of the Income Tax Appellate Tribunal (ITAT) in a transfer pricing adjustment case. The appellant, a subsidiary of a Japanese company, argued its functional profile was that of a service provider, not a trader. However, the ITAT determined the appellant's activities resembled trading, not that of a commission agent or broker, emphasizing transactions on a principal-to-principal basis. The Court affirmed this assessment, highlighting the need for comparables reflecting the appellant's functional profile, risk exposure, and working capital in determining the Arm's Length Price (ALP). The appeal was dismissed, providing clarity on selecting comparables for ALP determination. Case-Laws Income Tax Fri, 04 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249439