https://www.taxtmi.com/caselaws?id=790227 Transfer pricing adjustment based on the profit split method was found unsustainable on the existing record because the FAR profile, contractual framework, AE financials, employee base and risk allocation had not been examined conclusively. The attribution of functions relating to customer acquisition, negotiation, booking, payment processing and risk assumption required a fresh, evidence-based FAR analysis, and the reasoning for selecting the most appropriate method was not stated with sufficient clarity. The assessment order and the adjustment sustained by the DRP were set aside, and the matter was restored to the AO/TPO for fresh adjudication after giving the assessee an adequate opportunity of being heard. en-us Tue, 06 Jan 2026 00:00:00 +0530 Wed, 22 Apr 2026 08:47:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790227 Transfer pricing adjustment based on the profit split method was found unsustainable on the existing record because the FAR profile, contractual framework, AE financials, employee base and risk allocation had not been examined conclusively. The attribution of functions relating to customer acquisition, negotiation, booking, payment processing and risk assumption required a fresh, evidence-based FAR analysis, and the reasoning for selecting the most appropriate method was not stated with sufficient clarity. The assessment order and the adjustment sustained by the DRP were set aside, and the matter was restored to the AO/TPO for fresh adjudication after giving the assessee an adequate opportunity of being heard. Case-Laws Income Tax Tue, 06 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790227