https://www.taxtmi.com/caselaws?id=246184 The tribunal concluded that the Comparable Uncontrolled Price (CUP) method is the most appropriate for the transfer pricing adjustment case. The rejection of CUP and selection of Transactional Net Margin Method (TNMM) were deemed incorrect. The Transfer Pricing Officer (TPO) was directed to reassess using the CUP method, considering internal and external CUPs. The case was remanded to the TPO for fresh analysis, and the appeal was allowed for statistical purposes. The TPO was also instructed to apply the (+) or (-) 5% variation in determining the Arm's Length Price (ALP). en-us Wed, 29 Jan 2014 00:00:00 +0530 Fri, 18 Apr 2014 15:59:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246184 The tribunal concluded that the Comparable Uncontrolled Price (CUP) method is the most appropriate for the transfer pricing adjustment case. The rejection of CUP and selection of Transactional Net Margin Method (TNMM) were deemed incorrect. The Transfer Pricing Officer (TPO) was directed to reassess using the CUP method, considering internal and external CUPs. The case was remanded to the TPO for fresh analysis, and the appeal was allowed for statistical purposes. The TPO was also instructed to apply the (+) or (-) 5% variation in determining the Arm's Length Price (ALP). Case-Laws Income Tax Wed, 29 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246184