https://www.taxtmi.com/caselaws?id=181004 The appeal challenging the determination of arm's length price under section 92CA(3) for the assessment year 2002-03, focusing on the Cost Plus Method vs. Transaction Net Margin Method for international transactions, was dismissed. The Tribunal upheld the decision of the CIT(A) in favor of the assessee, confirming the use of the Cost Plus Method as appropriate based on functions performed, OECD guidelines, and past acceptance by the Transfer Pricing Officer. The addition made by the TPO was not upheld, and the CIT(A)'s order was found to have no infirmity. en-us Fri, 28 Jan 2011 00:00:00 +0530 Tue, 05 Apr 2016 18:45:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181004 The appeal challenging the determination of arm's length price under section 92CA(3) for the assessment year 2002-03, focusing on the Cost Plus Method vs. Transaction Net Margin Method for international transactions, was dismissed. The Tribunal upheld the decision of the CIT(A) in favor of the assessee, confirming the use of the Cost Plus Method as appropriate based on functions performed, OECD guidelines, and past acceptance by the Transfer Pricing Officer. The addition made by the TPO was not upheld, and the CIT(A)'s order was found to have no infirmity. Case-Laws Income Tax Fri, 28 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181004