https://www.taxtmi.com/caselaws?id=311312 ITAT Bangalore remanded TP adjustment matter to AO/TPO for verification. Assessee had APA for AY 2014-15 to 2018-19 but sought rollback of agreed margins to years not covered under APA. Though APA contained no rollback provision, tribunal found verification necessary to compare FAR analysis and international transactions between APA years and years under consideration. AO/TPO directed to verify identical nature of functions and risks, compare transactions, and compute ALP accordingly under Rule 10MA of IT Rules 1962. Appeals allowed for statistical purposes. en-us Thu, 21 Nov 2019 00:00:00 +0530 Wed, 20 Dec 2023 06:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311312 ITAT Bangalore remanded TP adjustment matter to AO/TPO for verification. Assessee had APA for AY 2014-15 to 2018-19 but sought rollback of agreed margins to years not covered under APA. Though APA contained no rollback provision, tribunal found verification necessary to compare FAR analysis and international transactions between APA years and years under consideration. AO/TPO directed to verify identical nature of functions and risks, compare transactions, and compute ALP accordingly under Rule 10MA of IT Rules 1962. Appeals allowed for statistical purposes. Case-Laws Income Tax Thu, 21 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311312