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2019 (8) TMI 647 - AT - Income TaxTP adjustment - international transaction of provision of investment/economic/business research services provided - comparable selection - HELD THAT:- Perusal of order of Ld. TPO for AY 2012- 13, would reveal that revised margins of USA & UK AEs have been accepted to be 1.05% & 1.71% respectively and the assessee has agreed for TP adjustment of ₹ 81 Lacs after considering 1% profit retention by its AEs being bare minimum that could be allowed to be retained by AEs as a risk free distributor. Similar methodology has been accepted by Ld. TPO for AY 2015-16 vide its order dated 31/10/2018 although with slight modification of minimum margin that could be retained by its AE. In AY 2015-16 the Ld. TPO, has restricted the margins of assessee’s AE to 0.5% of sales of the AEs. Therefore, keeping in view the rule of consistency and in view of the fact that this methodology has been accepted by the assessee as well as revenue, we direct TPO to adopt the same methodology for the year under consideration and work out TP adjustment by accepting AE’s margin to be 0.5%, as adopted in the latest order. The assessee is directed to provide the working of the same.
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