Mere profitability, responsible for enhancement of profits, does not indicate that transaction is at an ALP

Brief of the case: In these cross appeals Hon’ble HC have framed following questions of law: (a) Whether ITAT was correct in law in holding that the Transfer Pricing Officer could apply the CUP METHOD (comparable uncontrolled price method) to analize three international transactions? (b) Whether TPO could compute the arms length price ALP at nil on account of professional consultancy fee paid and management fee paid by the Appellant by using the Cup Method even though no comparable had been referred to by the TPO? (c) Whether ITAT was right in law in deleting the addition of Rs.1,61,36323/- ...