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        Case ID :
        Income Tax

        TP Adjustment - selection of most appropriate method (MAM) -...

        Tribunal Favors TNMM Over RPM for Transfer Pricing, Supports New Comparables, Rejects 3% Filter for Marketing Intensity.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3% Filter - The Tribunal upholds the adoption of Transactional Net Margin Method (TNMM) over Resale Price Method (RPM), citing subsequent TNMM usage and functional comparability. It supports the introduction of new comparables and the rejection of the 3% filter due to marketing intensity. The Tribunal confirms the deletion of additions based on selected comparables' margin comparison with the appellant.
                                Note: It is a system-generated summary and is for quick reference only.
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