DRP's TP Adjustment Criticized: Expense Reallocation Favors Assessee, Ignoring AE vs. Non-AE Revenue Disparities in Back Office Services.

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....TP adjustment made in respect of provision of back office services - In any case, we find the main grievance of the ld. DRP seems to be that AE revenue is only ₹ 19 Crores and Non-AE revenue is ₹ 176 Crores and salary cost of back office income unit seems to be more by 24% and requires allocation to non-AE unit. If this observation is to be accepted then, the same would only be beneficial to the assessee as the same would result in increase of margins for the AE BPO segment. This fact itself proves that the ld. DRP had not applied its mind at all on the basis of allocation of expenses between the AE units and the non-AE units.- AT....