Comparable earning commission couldn’t be taken as benchmark for an entity working on ‘cost-plus’ mo

IT/ILT : Where assessee operating as a procurement support services company for its AE i.e. GAP US, declared income on model of reimbursement of operating cost plus a markup of 15 per cent, TPO could not make addition to assessee's ALP by adopting a specific rate of commission on value of goods procured by GAP US directly from third party vendors from India