https://www.taxtmi.com/caselaws?id=465081 ITAT allowed the assessee's appeal, holding that the six comparables selected by the assessee satisfied the FAR analysis and could not be discarded merely for having losses or low margins. Upon inclusion of all comparables, the weighted average margin was 1.69%, below the 2% profit already attributed by the assessee to its Indian operations from offshore supply of goods; hence, no further profit attribution was warranted, and the AO was directed to accept the 2% attribution. Applying judicial consistency with earlier years, ITAT rejected the Revenue's grounds on characterization of receipts from core/fluid analysis and software maintenance contracts, and dismissed the Revenue's cross-appeal. en-us Mon, 28 Apr 2025 00:00:00 +0530 Tue, 02 Dec 2025 11:56:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465081 ITAT allowed the assessee's appeal, holding that the six comparables selected by the assessee satisfied the FAR analysis and could not be discarded merely for having losses or low margins. Upon inclusion of all comparables, the weighted average margin was 1.69%, below the 2% profit already attributed by the assessee to its Indian operations from offshore supply of goods; hence, no further profit attribution was warranted, and the AO was directed to accept the 2% attribution. Applying judicial consistency with earlier years, ITAT rejected the Revenue's grounds on characterization of receipts from core/fluid analysis and software maintenance contracts, and dismissed the Revenue's cross-appeal. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465081