Risk adjustments can be given only on company to company basis and not as thumb rule

Brief of the case:- The Hyderabad bench of the Income Tax Appellate Tribunal (Tribunal) recently pronounced its ruling in the case of ADP Private Limited Vs. DCIT (Hyderabad Bench), ITA No: 155/Hyd/2009 , on transfer pricing issues arising from provision of software services by the Taxpayer to its Associated enterprise (AE). The Tribunal ruled in favor of the Revenue upholding the adjustment proposed by the Transfer Pricing Officer (TPO). Facts of the case The Taxpayer is engaged in rendering software development services to its AE. During the AY 2004-05, the Taxpayer has provided software ser...