ITAT rejects high risks, high return claim of TPO; deletes TP addition as assessee beard same risk i

IT/ILT: Assessee was following two business models, which carried the same risk - where in the first model customers could enter into contract directly with assessee and in the other model they could enter into contract with its AE. In both business models assessee had to share same ratio of revenue with AE. Whether TPO could not made transfer pricing adjustment on the ground that assessee was entitled to larger share of proceeds when contract was directly entered into with customers if assessee