Transfer Pricing Adjustment: TPO to Reassess Benchmarking with Foreign Associated Enterprise as Tested Party for Onsite Development Fee.

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....TP adjustment - onsite development and project coordination fee’ - Associated enterprise can be considered as a tested party, in the present case. Accordingly, we direct the TPO to conduct fresh benchmarking analysis after considering foreign associated enterprise as the tested party and arrive at the arm’s length price for the international transaction pertaining to ‘onsite development and project coordination fee’. - AT....