https://www.taxtmi.com/caselaws?id=433322 The Revenue challenged the directions of the DRP for the assessment year 2006-07, questioning the rejection of functions carried out by the assessee and the basis for decision-making related to minimal risks. The TPO recomputed the ALP of international transactions with AEs, proposing adjustments based on unique intangibles and risks assumed by the assessee. The DRP directed the TPO to reevaluate the segmental margin, emphasizing accurate cost allocation. The Tribunal upheld the inclusion of Besant Raj International Ltd. in the comparable set, based on profitability in FY 03-04. The decision highlighted the legal principle regarding persistent loss-making status. en-us Wed, 09 Nov 2022 00:00:00 +0530 Wed, 25 Jan 2023 18:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433322 The Revenue challenged the directions of the DRP for the assessment year 2006-07, questioning the rejection of functions carried out by the assessee and the basis for decision-making related to minimal risks. The TPO recomputed the ALP of international transactions with AEs, proposing adjustments based on unique intangibles and risks assumed by the assessee. The DRP directed the TPO to reevaluate the segmental margin, emphasizing accurate cost allocation. The Tribunal upheld the inclusion of Besant Raj International Ltd. in the comparable set, based on profitability in FY 03-04. The decision highlighted the legal principle regarding persistent loss-making status. Case-Laws Income Tax Wed, 09 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433322