https://www.taxtmi.com/caselaws?id=213740 The case involved the rejection of the Comparable Uncontrolled Price (CUP) method for benchmarking Arm's Length Price (ALP) in international transactions. The Transactional Net Margin Method (TNMM) was adopted by the Transfer Pricing Officer (TPO), with the selection of comparables and negative working capital adjustment upheld. However, the high depreciation adjustment plea was accepted by the ITAT, directing a recomputation of ALP considering the high depreciation. The appeal was partly allowed, with the key decisions regarding the methods and adjustments being upheld except for the high depreciation adjustment, which was accepted for reconsideration. en-us Thu, 31 May 2012 00:00:00 +0530 Fri, 01 May 2026 18:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=213740 The case involved the rejection of the Comparable Uncontrolled Price (CUP) method for benchmarking Arm's Length Price (ALP) in international transactions. The Transactional Net Margin Method (TNMM) was adopted by the Transfer Pricing Officer (TPO), with the selection of comparables and negative working capital adjustment upheld. However, the high depreciation adjustment plea was accepted by the ITAT, directing a recomputation of ALP considering the high depreciation. The appeal was partly allowed, with the key decisions regarding the methods and adjustments being upheld except for the high depreciation adjustment, which was accepted for reconsideration. Case-Laws Income Tax Thu, 31 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=213740