https://www.taxtmi.com/caselaws?id=331983 The High Court of Delhi upheld the decision of the Income Tax Appellate Tribunal (ITAT) in a case involving the determination of Arms Length Price (ALP) in international transactions. The Assessee's use of the Transactional Net Margin Method (TNMM) was challenged by the Transfer Pricing Officer (TPO) who applied the Comparable Uncontrolled Price (CUP) method. The Court agreed with the ITAT that the agreement with the Associated Enterprise should be viewed as a whole, rejecting the TPO's approach. Consequently, the Court dismissed the Revenue's appeals, finding no substantial question of law to be determined. en-us Thu, 28 Jul 2016 00:00:00 +0530 Wed, 07 Sep 2016 10:19:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331983 The High Court of Delhi upheld the decision of the Income Tax Appellate Tribunal (ITAT) in a case involving the determination of Arms Length Price (ALP) in international transactions. The Assessee's use of the Transactional Net Margin Method (TNMM) was challenged by the Transfer Pricing Officer (TPO) who applied the Comparable Uncontrolled Price (CUP) method. The Court agreed with the ITAT that the agreement with the Associated Enterprise should be viewed as a whole, rejecting the TPO's approach. Consequently, the Court dismissed the Revenue's appeals, finding no substantial question of law to be determined. Case-Laws Income Tax Thu, 28 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331983