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The ITAT determined that the Transactional Net Margin Method (TNMM) was the most appropriate method for benchmarking international goods sale/export transactions, overturning the revenue's Comparable Uncontrolled Price (CUP) method. The transfer pricing adjustment was set aside, and the matter was remanded to the assessing officer to determine the arm's length price using TNMM. The appellate tribunal ruled in favor of the assessee, allowing the appeal for statistical purposes and directing a fresh assessment based on the approved transfer pricing methodology.
The ITAT determined that the Transactional Net Margin Method (TNMM) was the most appropriate method for benchmarking international goods sale/export transactions, overturning the revenue's Comparable Uncontrolled Price (CUP) method. The transfer pricing adjustment was set aside, and the matter was remanded to the assessing officer to determine the arm's length price using TNMM. The appellate tribunal ruled in favor of the assessee, allowing the appeal for statistical purposes and directing a fresh assessment based on the approved transfer pricing methodology.
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