https://www.taxtmi.com/caselaws?id=779638 HC upheld the ITAT's approach that the Advance Pricing Agreement (AP Agreement) entered with CBDT is applicable to the taxpayer's international transactions for the year under assessment where Functions, Assets and Risks (FAR) remain unchanged. The court noted Revenue did not dispute lack of FAR change or the AP Agreement's consolidated 19.26% margin, and held the TPO must consider the FAR and arm's-length parameters from the AP Agreement for the year under scrutiny, giving persuasive effect to the AP even if it covers specific other years. en-us Wed, 17 Sep 2025 00:00:00 +0530 Thu, 09 Oct 2025 08:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779638 HC upheld the ITAT's approach that the Advance Pricing Agreement (AP Agreement) entered with CBDT is applicable to the taxpayer's international transactions for the year under assessment where Functions, Assets and Risks (FAR) remain unchanged. The court noted Revenue did not dispute lack of FAR change or the AP Agreement's consolidated 19.26% margin, and held the TPO must consider the FAR and arm's-length parameters from the AP Agreement for the year under scrutiny, giving persuasive effect to the AP even if it covers specific other years. Case-Laws Income Tax Wed, 17 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779638