https://www.taxtmi.com/caselaws?id=351592 In transfer pricing benchmarking, reimbursement of an arbitration award paid on behalf of an associated enterprise was not treated as part of the assessee's operating cost base for margin computation, as the payment was reimbursed and did not warrant inclusion in the tested party's cost base. The Tribunal also accepted that a captive service provider may be entitled to risk adjustment under the TNMM where comparables operate with materially different risk profiles, and such adjustment is required to place the tested party and comparables on a comparable footing when supported by a reasoned basis and reliable data. The transfer pricing additions were therefore interfered with only to the extent of these issues. en-us Wed, 22 Nov 2017 00:00:00 +0530 Mon, 14 May 2018 14:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=351592 In transfer pricing benchmarking, reimbursement of an arbitration award paid on behalf of an associated enterprise was not treated as part of the assessee's operating cost base for margin computation, as the payment was reimbursed and did not warrant inclusion in the tested party's cost base. The Tribunal also accepted that a captive service provider may be entitled to risk adjustment under the TNMM where comparables operate with materially different risk profiles, and such adjustment is required to place the tested party and comparables on a comparable footing when supported by a reasoned basis and reliable data. The transfer pricing additions were therefore interfered with only to the extent of these issues. Case-Laws Income Tax Wed, 22 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=351592