In the result, the appeal of the assessee is partly allowed for statistical purposes
Bench: Shri Waseem Ahmed & Shri Keshav Dubey
transfer pricing. In holding so, the learned DRP referred various case laws. 21. Being aggrieved by the order of the learned DRP/AO/TPO, the assessee is in appeal before us. 22. The learned AR before us argued that the TPO erred in benchmarking the outstanding receivables as a separate international transaction and proposing an adjustment