https://www.taxtmi.com/caselaws?id=339312 The Tribunal found that the adjustments made by the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) lacked a clear basis and did not adequately consider the differing business models and risk profiles of the segments. The matter was remanded to the TPO/AO for a fresh determination of the Arm's Length Price (ALP), instructing them to consider reasonable comparables and conduct a thorough functional and risk analysis. The appeals were partly allowed, and the case was remanded for further verification and investigation. en-us Wed, 04 Jan 2017 00:00:00 +0530 Mon, 20 Feb 2017 12:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339312 The Tribunal found that the adjustments made by the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) lacked a clear basis and did not adequately consider the differing business models and risk profiles of the segments. The matter was remanded to the TPO/AO for a fresh determination of the Arm's Length Price (ALP), instructing them to consider reasonable comparables and conduct a thorough functional and risk analysis. The appeals were partly allowed, and the case was remanded for further verification and investigation. Case-Laws Income Tax Wed, 04 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339312