https://www.taxtmi.com/caselaws?id=208108 ITAT, Mumbai - AT dismissed the Revenue appeal, upholding the CIT(A)'s decision that no transfer pricing adjustment was warranted. The Tribunal found the TPO and AO erred in applying TNMM to enterprise-level operating margins rather than net profit margins from the international transaction(s) as required by s.92F(ii); non-operational income should have been excluded, which would have reduced the margin variation below 5% under the CBDT guidance. The AO's application of TNMM was therefore incorrect. en-us Fri, 15 Jan 2010 00:00:00 +0530 Fri, 14 Nov 2025 14:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208108 ITAT, Mumbai - AT dismissed the Revenue appeal, upholding the CIT(A)'s decision that no transfer pricing adjustment was warranted. The Tribunal found the TPO and AO erred in applying TNMM to enterprise-level operating margins rather than net profit margins from the international transaction(s) as required by s.92F(ii); non-operational income should have been excluded, which would have reduced the margin variation below 5% under the CBDT guidance. The AO's application of TNMM was therefore incorrect. Case-Laws Income Tax Fri, 15 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208108