https://www.taxtmi.com/caselaws?id=71369 The Tribunal partly allowed the appeal, rejecting the use of the CUP method and remitting the case to the TPO for fresh adjudication under the TNMM method, considering the taxpayer's unique business model. It upheld the taxpayer's grievance regarding the non-consideration of the +/- 5% variation under s. 92C(2) of the Act. The Tribunal emphasized the need for a fair opportunity for the taxpayer to present arguments and data, ensuring a thorough resolution of the transfer pricing issues. The Tribunal did not address the issue of interest under ss. 234B and 234C, focusing instead on procedural fairness and transfer pricing adjustments. en-us Thu, 12 Mar 2009 00:00:00 +0530 Thu, 26 Oct 2023 11:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71369 The Tribunal partly allowed the appeal, rejecting the use of the CUP method and remitting the case to the TPO for fresh adjudication under the TNMM method, considering the taxpayer's unique business model. It upheld the taxpayer's grievance regarding the non-consideration of the +/- 5% variation under s. 92C(2) of the Act. The Tribunal emphasized the need for a fair opportunity for the taxpayer to present arguments and data, ensuring a thorough resolution of the transfer pricing issues. The Tribunal did not address the issue of interest under ss. 234B and 234C, focusing instead on procedural fairness and transfer pricing adjustments. Case-Laws Income Tax Thu, 12 Mar 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71369