https://www.taxtmi.com/caselaws?id=177463 Comparable Uncontrolled Price analysis was found unsuitable for isolated export, import and commission transactions where the controlled and uncontrolled dealings involved material functional, geographical, volume, timing and risk differences. Simple internal price comparison could not support transfer pricing adjustments because suitable adjustments were not possible and the commission arrangements were not functionally comparable. The Transactional Net Margin Method, applied to the assessee's closely linked transactions as part of a single business activity, was treated as the more appropriate method on the facts, particularly since the overall operating margin was higher than that of the comparables and the segmental additions were therefore not sustainable. en-us Fri, 30 May 2014 00:00:00 +0530 Sat, 09 Jan 2016 16:33:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177463 Comparable Uncontrolled Price analysis was found unsuitable for isolated export, import and commission transactions where the controlled and uncontrolled dealings involved material functional, geographical, volume, timing and risk differences. Simple internal price comparison could not support transfer pricing adjustments because suitable adjustments were not possible and the commission arrangements were not functionally comparable. The Transactional Net Margin Method, applied to the assessee's closely linked transactions as part of a single business activity, was treated as the more appropriate method on the facts, particularly since the overall operating margin was higher than that of the comparables and the segmental additions were therefore not sustainable. Case-Laws Income Tax Fri, 30 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177463