https://www.taxtmi.com/caselaws?id=466368 Transfer pricing dispute concerned application of a bilateral advance pricing agreement (BAPA) rate agreed for ITeS transactions with a UK associated enterprise to parallel transactions with a USA associated enterprise. The tribunal accepted the parties' and TPO's entitylevel benchmarking premise that functions, assets and risks were materially similar across UK and USA dealings, noted a BAPAaccepted ITeS margin of 16% versus the AO/TPO's 23%, and directed the AO/TPO to adopt the BAPA rate for the USA AE transactions and compute transfer pricing adjustment accordingly. en-us Fri, 28 Feb 2025 00:00:00 +0530 Tue, 03 Feb 2026 22:11:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466368 Transfer pricing dispute concerned application of a bilateral advance pricing agreement (BAPA) rate agreed for ITeS transactions with a UK associated enterprise to parallel transactions with a USA associated enterprise. The tribunal accepted the parties' and TPO's entitylevel benchmarking premise that functions, assets and risks were materially similar across UK and USA dealings, noted a BAPAaccepted ITeS margin of 16% versus the AO/TPO's 23%, and directed the AO/TPO to adopt the BAPA rate for the USA AE transactions and compute transfer pricing adjustment accordingly. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466368