https://www.taxtmi.com/caselaws?id=416170 The Tribunal partially allowed the assessee's appeal, directing a fresh Transfer Pricing study treating the assessee as a marketing service provider and emphasizing consistency in the business profile across assessment years. The re-characterization of the business profile by the Transfer Pricing Officer was deemed inappropriate, and various issues such as segmentation of revenue/costs, use of data, selection of comparables, and risk adjustments were remanded for reconsideration in the new study. The Tribunal also highlighted the non-compliance with Dispute Resolution Panel directions, requiring the AO to address these issues in the fresh assessment. en-us Wed, 01 Dec 2021 00:00:00 +0530 Fri, 09 Sep 2022 11:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416170 The Tribunal partially allowed the assessee's appeal, directing a fresh Transfer Pricing study treating the assessee as a marketing service provider and emphasizing consistency in the business profile across assessment years. The re-characterization of the business profile by the Transfer Pricing Officer was deemed inappropriate, and various issues such as segmentation of revenue/costs, use of data, selection of comparables, and risk adjustments were remanded for reconsideration in the new study. The Tribunal also highlighted the non-compliance with Dispute Resolution Panel directions, requiring the AO to address these issues in the fresh assessment. Case-Laws Income Tax Wed, 01 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416170