https://www.taxtmi.com/caselaws?id=180522 The Tribunal remitted the case back to the Assessing Officer/Transfer Pricing Officer, directing them to provide detailed justifications for preferring the Transactional Net Margin Method over the Comparable Uncontrolled Price method. The AO/TPO must also explain why the CUP method is deemed inappropriate, justify the adjustments made, and determine if the assessee is entitled to the benefit of Section 92C(2). The appeal of the assessee was allowed for statistical purposes, and the stay petition was considered infructuous, with the AO/TPO instructed to allow the assessee an opportunity to present its case. en-us Wed, 30 Nov 2011 00:00:00 +0530 Mon, 28 Mar 2016 15:37:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180522 The Tribunal remitted the case back to the Assessing Officer/Transfer Pricing Officer, directing them to provide detailed justifications for preferring the Transactional Net Margin Method over the Comparable Uncontrolled Price method. The AO/TPO must also explain why the CUP method is deemed inappropriate, justify the adjustments made, and determine if the assessee is entitled to the benefit of Section 92C(2). The appeal of the assessee was allowed for statistical purposes, and the stay petition was considered infructuous, with the AO/TPO instructed to allow the assessee an opportunity to present its case. Case-Laws Income Tax Wed, 30 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180522