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The ITAT held that the assessee's selection of internal TNMM as the Most Appropriate Method for determining arm's length price in specified domestic transactions could not be rejected without cogent reasons. The TPO and SCN failed to provide any rationale for rejecting the internal TNMM and substituting it with an external TNMM using ten comparables. The tribunal emphasized that internal TNMM is a recognized and accepted method, and summary dismissal of the assessee's approach was unjustified. Consequently, the impugned transfer pricing adjustment based on external TNMM was set aside, and the assessee's appeal was allowed.
The ITAT held that the assessee's selection of internal TNMM as the Most Appropriate Method for determining arm's length price in specified domestic transactions could not be rejected without cogent reasons. The TPO and SCN failed to provide any rationale for rejecting the internal TNMM and substituting it with an external TNMM using ten comparables. The tribunal emphasized that internal TNMM is a recognized and accepted method, and summary dismissal of the assessee's approach was unjustified. Consequently, the impugned transfer pricing adjustment based on external TNMM was set aside, and the assessee's appeal was allowed.
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