Assessee's Transfer Pricing Report Rejected for Non-Compliance; Incorrect Profit Split Method Application and Lack of Benchmarking Noted.

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....TP - The transfer pricing report furnished by the assessee is not in accordance with rules prescribed in this regard - The PSM has not been correctly applied as per law - No bench marking has been done – thus, it cannot be approved - the most appropriate method in this type of function/transaction would be profit split method only - AT....