Sec. 92B of Income Tax Act, 1961—Transfer Pricing—Detailed FAR analysis has to be carried out to identify all the functions of resident tax payer company and the non-resident AEs pertaining to all the international transactions, thus, FAR analysis is the key which needs to be seen what kind of functions is being carried out by the AE in India, the nature of assets which have been deployed and the risk which have been assumed and in case of assessee at several places parent AE of the assessee-company has not carried out any function in India and had not assumed any risk in India and even for the license for use of trademark, no royalty has been paid, hence, no benefit whatsoever has accrued to the parent AE, accordingly, it is very difficult to attribute any kind of Arm's Length compensation which is supposed to be made by the AE to the assessee company. - PEPSICO INDIA HOLDINGS (P.) LTD. V/s DY. CIT - [2020] 183 ITD 196 (ITAT-DELHI)