In transfer pricing, no risk adjustment desired for unquantified risk being no effect on ALP adjustment

Brief of the Case ITAT Jaipur held In the case of Integrated Decisions and Systems (India) Private Limited vs. ITO that these risk adjustments are only theoretically which cannot be quantified in terms of any calculation to conclude the exact adjustment in ALP. The ld counsel of the assessee had not able to quantify these adjustments in terms of statistical calculation and has not been able to demonstrate the effect of these risks on adjustment of ALP. The TPO was right by accepting the arithmetic mean of comparable of comparable companies if any risk as claimed by the appellant was concerned;...