https://www.taxtmi.com/caselaws?id=386153 The Tribunal's order directed the Transfer Pricing Officer (TPO) to make adjustments only on related party transactions, not all transactions, following a previous court ruling. Companies were excluded from comparables based on functional differences, with the exclusion of M/s. Genesys and M/s. Cosmic Global Ltd. upheld. The issue of excluding a company based on high profits was deemed academic. The Tribunal allowed the appeal on the issue of risk adjustment, remanding it to the Assessing Officer. The appeal was ultimately dismissed as the raised issues did not present substantial questions of law for consideration. en-us Tue, 03 Sep 2019 00:00:00 +0530 Sat, 21 Sep 2019 18:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386153 The Tribunal's order directed the Transfer Pricing Officer (TPO) to make adjustments only on related party transactions, not all transactions, following a previous court ruling. Companies were excluded from comparables based on functional differences, with the exclusion of M/s. Genesys and M/s. Cosmic Global Ltd. upheld. The issue of excluding a company based on high profits was deemed academic. The Tribunal allowed the appeal on the issue of risk adjustment, remanding it to the Assessing Officer. The appeal was ultimately dismissed as the raised issues did not present substantial questions of law for consideration. Case-Laws Income Tax Tue, 03 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386153