https://www.taxtmi.com/caselaws?id=219543 The Tribunal partially allowed the assessee's appeal, ruling the reopening of the assessment invalid. The internal Transactional Net Margin Method (TNMM) analysis was deemed appropriate, leading to a recalculated upward adjustment to the Arm's Length Price (ALP) of Rs. 10,50,986.23, significantly lower than the initial adjustment. The Tribunal emphasized the necessity of tangible reasons for reassessment under Section 147 of the Income-tax Act, 1961, and upheld the use of internal comparables for transfer pricing analysis. en-us Thu, 19 Jul 2012 00:00:00 +0530 Tue, 18 Dec 2012 15:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219543 The Tribunal partially allowed the assessee's appeal, ruling the reopening of the assessment invalid. The internal Transactional Net Margin Method (TNMM) analysis was deemed appropriate, leading to a recalculated upward adjustment to the Arm's Length Price (ALP) of Rs. 10,50,986.23, significantly lower than the initial adjustment. The Tribunal emphasized the necessity of tangible reasons for reassessment under Section 147 of the Income-tax Act, 1961, and upheld the use of internal comparables for transfer pricing analysis. Case-Laws Income Tax Thu, 19 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219543