Court Selects Berry Ratio for Transfer Pricing; Rejects Comparisons Due to Unique Assessee Expenses Benefiting Associated Enterprises.

Transfer pricing adjustment - Berry ratio selected as most appropriate method for determining the ALP - since the assessee had incurred abnormal expenses for specific activities conducted by the assessee for the predominant benefit of the assessee’s AEs, the decisions cited by the Ld. A.R. are rejected because in those cases only routine expenses were incurred unlike the case of the assessee - AT .....

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