https://www.taxtmi.com/caselaws?id=399266 The Tribunal upheld the DRP's directions and the AO's final assessment order, dismissing the appeal. The key points include the emphasis on annual comparability assessment based on FAR analysis and the rejection of PAE Ltd. as a comparable due to significant product and market differences. The decision highlights the importance of realistic and functionally comparable transfer pricing adjustments. en-us Wed, 09 Sep 2020 00:00:00 +0530 Wed, 07 Oct 2020 11:39:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399266 The Tribunal upheld the DRP's directions and the AO's final assessment order, dismissing the appeal. The key points include the emphasis on annual comparability assessment based on FAR analysis and the rejection of PAE Ltd. as a comparable due to significant product and market differences. The decision highlights the importance of realistic and functionally comparable transfer pricing adjustments. Case-Laws Income Tax Wed, 09 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399266