https://www.taxtmi.com/caselaws?id=280977 The court partially allowed the application for rectification of an order related to Transfer Pricing Adjustment. It clarified that there was no functional similarity between the assessee and another entity, emphasizing differences in risk assumption and revenue models. The court noted the assessee's provision of support services compared to the other entity's principal-to-principal operations. Despite some similarities in revenue models, the court concluded they were not identical. The Transfer Pricing Analysis for future years would proceed based on the clarified distinctions, as per the court's decision. en-us Thu, 11 Oct 2018 00:00:00 +0530 Wed, 29 May 2019 06:54:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280977 The court partially allowed the application for rectification of an order related to Transfer Pricing Adjustment. It clarified that there was no functional similarity between the assessee and another entity, emphasizing differences in risk assumption and revenue models. The court noted the assessee's provision of support services compared to the other entity's principal-to-principal operations. Despite some similarities in revenue models, the court concluded they were not identical. The Transfer Pricing Analysis for future years would proceed based on the clarified distinctions, as per the court's decision. Case-Laws Income Tax Thu, 11 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280977