https://www.taxtmi.com/caselaws?id=307558 In a transfer pricing dispute, an Advance Pricing Agreement may guide the determination for a year outside its direct coverage if the functional, asset and risk profile remains the same. The Tribunal noted that the agreement addressed the covered international transactions and the most appropriate method, and that consistent decisions require comparison of the disputed year's FAR profile with the agreement years before applying that methodology. The assessee was directed to produce the relevant compliance documents, and the Assessing Officer/TPO was directed to examine FAR similarity and apply the agreed method if the profiles match. en-us Fri, 28 Aug 2020 00:00:00 +0530 Fri, 21 Apr 2023 21:57:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307558 In a transfer pricing dispute, an Advance Pricing Agreement may guide the determination for a year outside its direct coverage if the functional, asset and risk profile remains the same. The Tribunal noted that the agreement addressed the covered international transactions and the most appropriate method, and that consistent decisions require comparison of the disputed year's FAR profile with the agreement years before applying that methodology. The assessee was directed to produce the relevant compliance documents, and the Assessing Officer/TPO was directed to examine FAR similarity and apply the agreed method if the profiles match. Case-Laws Income Tax Fri, 28 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307558