https://www.taxtmi.com/highlights?id=98444 Where transfer pricing analysis was applied uniformly to all international transactions and no separate benchmarking was carried out for non-US based AE transactions, the Tribunal treated the BAPA margin as a reliable persuasive benchmark. It noted that the Revenue failed to show any material difference in the FAR profile of the non-US transactions from those covered by the BAPA. Applying the principle of consistency, the Tribunal accepted the assessee's claim and directed adoption of the BAPA margin for determining the arm's length price of the non-US based AE transactions as well. The appeals were allowed. en-us Sat, 04 Apr 2026 10:55:25 +0530 Sat, 04 Apr 2026 10:55:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98444 Where transfer pricing analysis was applied uniformly to all international transactions and no separate benchmarking was carried out for non-US based AE transactions, the Tribunal treated the BAPA margin as a reliable persuasive benchmark. It noted that the Revenue failed to show any material difference in the FAR profile of the non-US transactions from those covered by the BAPA. Applying the principle of consistency, the Tribunal accepted the assessee's claim and directed adoption of the BAPA margin for determining the arm's length price of the non-US based AE transactions as well. The appeals were allowed. Highlights Income Tax Sat, 04 Apr 2026 10:55:25 +0530 https://www.taxtmi.com/highlights?id=98444