TPO Adjusts Transfer Pricing Using 23% OP/OC Ratio; 3% Allowance for Delays and Services in Non-AE Business.

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....Transfer pricing adjustment - TPO made an adjustment taking in to consideration the OP/OC for AE segment at 23% [26%(-)3%,an allowance for delay in receivables and after sales services and other efforts made under the non-AE business] - some reasonable comparables should be selected after considering the FAR analysis of such comparable and only then exercise of determining ALP should be completed - AT....