https://www.taxtmi.com/caselaws?id=238095 The Tribunal upheld the decision to exclude "Rites Limited" as a comparable due to its unique government-backed nature, affirming that it was not suitable for benchmarking against the assessee. The correct application of the Transactional Net Margin Method (TNMM) without including extraordinary expenses showed that the assessee's transactions were at arm's length. The Tribunal also supported the use of internal Comparable Uncontrolled Price (CUP) data alongside TNMM, emphasizing the importance of selecting the appropriate profit level indicator (PLI). As a result, the Revenue's appeal was dismissed. en-us Wed, 12 Jun 2013 00:00:00 +0530 Fri, 10 Apr 2026 15:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=238095 The Tribunal upheld the decision to exclude "Rites Limited" as a comparable due to its unique government-backed nature, affirming that it was not suitable for benchmarking against the assessee. The correct application of the Transactional Net Margin Method (TNMM) without including extraordinary expenses showed that the assessee's transactions were at arm's length. The Tribunal also supported the use of internal Comparable Uncontrolled Price (CUP) data alongside TNMM, emphasizing the importance of selecting the appropriate profit level indicator (PLI). As a result, the Revenue's appeal was dismissed. Case-Laws Income Tax Wed, 12 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=238095