https://www.taxtmi.com/caselaws?id=356218 The Tribunal upheld the CIT (A)'s decision, ruling that the taxpayer is a business support services provider, not a trader. The inclusion of Free on Board (FOB) value in the taxpayer's operating cost was deemed unsustainable under the Transactional Net Margin Method. The Tribunal emphasized the taxpayer's different functional and risk profile, adequate compensation, and the principle of consistency in transfer pricing analysis. The Revenue's appeal was dismissed, affirming the taxpayer's classification and rejecting the FOB value inclusion. en-us Wed, 21 Feb 2018 00:00:00 +0530 Tue, 27 Feb 2018 07:12:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=356218 The Tribunal upheld the CIT (A)'s decision, ruling that the taxpayer is a business support services provider, not a trader. The inclusion of Free on Board (FOB) value in the taxpayer's operating cost was deemed unsustainable under the Transactional Net Margin Method. The Tribunal emphasized the taxpayer's different functional and risk profile, adequate compensation, and the principle of consistency in transfer pricing analysis. The Revenue's appeal was dismissed, affirming the taxpayer's classification and rejecting the FOB value inclusion. Case-Laws Income Tax Wed, 21 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=356218