https://www.taxtmi.com/caselaws?id=205212 The Tribunal affirmed the CIT(A)'s decision in a transfer pricing case, upholding the adjustments made by the tax authorities. The primary issue was the correctness of the transfer pricing adjustment under the TNMM method, with the TPO suggesting a mark-up on total costs. The assessee's use of estimated costs without proper documentation was deemed unjustified, leading to the dismissal of the appeal. The burden of proof rested on the assessee, who failed to substantiate the method used, resulting in the decision favoring the tax authorities. en-us Fri, 22 Jul 2011 00:00:00 +0530 Mon, 05 Sep 2011 13:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205212 The Tribunal affirmed the CIT(A)'s decision in a transfer pricing case, upholding the adjustments made by the tax authorities. The primary issue was the correctness of the transfer pricing adjustment under the TNMM method, with the TPO suggesting a mark-up on total costs. The assessee's use of estimated costs without proper documentation was deemed unjustified, leading to the dismissal of the appeal. The burden of proof rested on the assessee, who failed to substantiate the method used, resulting in the decision favoring the tax authorities. Case-Laws Income Tax Fri, 22 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205212