https://www.taxtmi.com/caselaws?id=186016 The Tribunal allowed the assessee's appeal against the Dispute Resolution Panel's decision on the computation of Arm's Length Price (ALP) under the Income-tax Act. The rejection of the Comparable Uncontrolled Price (CUP) method and the adoption of the Transactional Net Margin Method (TNMM) were contested, highlighting the non-comparability of selected comparables. The Tribunal found the comparables inadequate and remitted the matter for reconsideration by the Assessing Officer/Transfer Pricing Officer. The decision favored the assessee, granting a fair hearing and requiring a reassessment of the ALP computation method and comparables. en-us Thu, 26 Apr 2012 00:00:00 +0530 Mon, 05 Sep 2016 17:26:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186016 The Tribunal allowed the assessee's appeal against the Dispute Resolution Panel's decision on the computation of Arm's Length Price (ALP) under the Income-tax Act. The rejection of the Comparable Uncontrolled Price (CUP) method and the adoption of the Transactional Net Margin Method (TNMM) were contested, highlighting the non-comparability of selected comparables. The Tribunal found the comparables inadequate and remitted the matter for reconsideration by the Assessing Officer/Transfer Pricing Officer. The decision favored the assessee, granting a fair hearing and requiring a reassessment of the ALP computation method and comparables. Case-Laws Income Tax Thu, 26 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186016