https://www.taxtmi.com/caselaws?id=256063 The Tribunal rejected the appellant's use of the Transactional Net Margin Method (TNMM) on entity level for international transactions related to the 'Sale of finished goods'. It approved the Transfer Pricing Officer's use of the Comparable Uncontrolled Price (CUP) method but directed consideration of the average price of comparable uncontrolled transactions. Regarding commission payments to associated enterprises (AEs), the Tribunal held that the Transfer Pricing Officer should only determine the Arm's Length Price (ALP) and not decide on the existence of services. The matter was remitted to the authorities for redetermination in line with legal principles. en-us Fri, 30 Jan 2015 00:00:00 +0530 Tue, 03 Feb 2015 06:02:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256063 The Tribunal rejected the appellant's use of the Transactional Net Margin Method (TNMM) on entity level for international transactions related to the 'Sale of finished goods'. It approved the Transfer Pricing Officer's use of the Comparable Uncontrolled Price (CUP) method but directed consideration of the average price of comparable uncontrolled transactions. Regarding commission payments to associated enterprises (AEs), the Tribunal held that the Transfer Pricing Officer should only determine the Arm's Length Price (ALP) and not decide on the existence of services. The matter was remitted to the authorities for redetermination in line with legal principles. Case-Laws Income Tax Fri, 30 Jan 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256063