https://www.taxtmi.com/highlights?id=60112 TP Adjustment - risk based assessment and selection of comparable - The glaring fallacy in the approach of the TPO lies on the fact that he has adopted FOB cost of goods procured from India by the AEs through the assessee as cost base. In our considered view, this approach of the TPO is in complete disregard to the functional profile of the assessee. The assessee operates in a limited risk environment providing routine support services to group entities and accordingly, entitled to be remunerated based on assured return. - AT en-us Thu, 14 Oct 2021 18:21:44 +0530 Thu, 14 Oct 2021 18:21:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=60112 TP Adjustment - risk based assessment and selection of comparable - The glaring fallacy in the approach of the TPO lies on the fact that he has adopted FOB cost of goods procured from India by the AEs through the assessee as cost base. In our considered view, this approach of the TPO is in complete disregard to the functional profile of the assessee. The assessee operates in a limited risk environment providing routine support services to group entities and accordingly, entitled to be remunerated based on assured return. - AT Highlights Income Tax Thu, 14 Oct 2021 18:21:44 +0530 https://www.taxtmi.com/highlights?id=60112