ITAT Revises DAPE Profit Attribution to 12 Per cent

The Delhi ITAT partly allowed the appeals of BBC Global News Ltd., holding that the Revenue was justified in departing from the 8.75% attribution rate agreed under earlier MAP proceedings because the Indian DAPE was performing functions beyond those disclosed in the transfer pricing documentation. 

However, the Tribunal found the Revenue's enhancement to 15% excessive and restricted the profit attribution to 12% of advertisement revenue.