https://www.taxtmi.com/caselaws?id=797789 Transfer-pricing characterisation of an international transaction involving purchase of services for resale requires examination of the taxpayer's functions, assets and risks. Treating the taxpayer as an information technology enabled service provider without cogent reasons, and without explaining departure from its earlier reseller characterisation despite no material factual change, was unsustainable. Although the Advance Pricing Agreement did not cover the relevant year, its functional analysis, acceptance of the Transactional Net Margin Method and reseller characterisation were relevant for reconsideration. The transfer-pricing issue was restored for fresh determination of the arm's length price under applicable law. en-us Mon, 24 Aug 2026 00:00:00 +0530 Thu, 27 Aug 2026 08:28:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797789 Transfer-pricing characterisation of an international transaction involving purchase of services for resale requires examination of the taxpayer's functions, assets and risks. Treating the taxpayer as an information technology enabled service provider without cogent reasons, and without explaining departure from its earlier reseller characterisation despite no material factual change, was unsustainable. Although the Advance Pricing Agreement did not cover the relevant year, its functional analysis, acceptance of the Transactional Net Margin Method and reseller characterisation were relevant for reconsideration. The transfer-pricing issue was restored for fresh determination of the arm's length price under applicable law. Case-Laws Income Tax Mon, 24 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797789