https://www.taxtmi.com/caselaws?id=255865 Transfer pricing characterisation could not be sustained on incomplete material where the record lacked the memorandum and articles, the governing agreement, and supporting evidence for the services, billing basis, and duties performed. Without a proper functional, asset and risk analysis, the assessee's profile as a business support or technical support service provider could not be conclusively tested, and the comparables exercise also depended on the same factual foundation. The matter was therefore restored to the Transfer Pricing Officer for fresh examination of the documents, functions performed, and arm's length price analysis. en-us Thu, 22 Jan 2015 00:00:00 +0530 Thu, 29 Jan 2015 06:32:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=255865 Transfer pricing characterisation could not be sustained on incomplete material where the record lacked the memorandum and articles, the governing agreement, and supporting evidence for the services, billing basis, and duties performed. Without a proper functional, asset and risk analysis, the assessee's profile as a business support or technical support service provider could not be conclusively tested, and the comparables exercise also depended on the same factual foundation. The matter was therefore restored to the Transfer Pricing Officer for fresh examination of the documents, functions performed, and arm's length price analysis. Case-Laws Income Tax Thu, 22 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=255865