https://www.taxtmi.com/caselaws?id=171030 The Tribunal partially allowed the appellant's appeal challenging the Arm's Length Price adjustment, focusing on the comparability of Genesys International as a comparable entity. The Tribunal adjusted the Profit Level Indicators between 20% and 32.8% to reach a fair decision at 23%, directing the Assessing Officer to compute the adjustment accordingly. This case underscores the significance of evaluating functional comparability in Transfer Pricing analysis for accurate Arm's Length Price adjustments. en-us Fri, 12 Dec 2014 00:00:00 +0530 Sat, 28 Feb 2015 10:53:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=171030 The Tribunal partially allowed the appellant's appeal challenging the Arm's Length Price adjustment, focusing on the comparability of Genesys International as a comparable entity. The Tribunal adjusted the Profit Level Indicators between 20% and 32.8% to reach a fair decision at 23%, directing the Assessing Officer to compute the adjustment accordingly. This case underscores the significance of evaluating functional comparability in Transfer Pricing analysis for accurate Arm's Length Price adjustments. Case-Laws Income Tax Fri, 12 Dec 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=171030