https://www.taxtmi.com/caselaws?id=186271 The Tribunal upheld the Transfer Pricing Officer's adoption of the Transactional Net Margin Method (TNMM) over the Cost Plus Method (CPM) or Comparable Uncontrolled Price (CUP) method due to lack of reliable data. It directed the exclusion of certain companies from comparables and instructed reevaluation of related party transactions for comparability. The Tribunal addressed issues of multiple year data, TPO's power under section 133(6), and filters adopted, deeming them academic. It directed consideration of foreign exchange fluctuations and risk adjustments in computing the Arm's Length Price (ALP) and allowed the appeal partly for statistical purposes. en-us Wed, 16 Mar 2016 00:00:00 +0530 Tue, 13 Sep 2016 14:13:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186271 The Tribunal upheld the Transfer Pricing Officer's adoption of the Transactional Net Margin Method (TNMM) over the Cost Plus Method (CPM) or Comparable Uncontrolled Price (CUP) method due to lack of reliable data. It directed the exclusion of certain companies from comparables and instructed reevaluation of related party transactions for comparability. The Tribunal addressed issues of multiple year data, TPO's power under section 133(6), and filters adopted, deeming them academic. It directed consideration of foreign exchange fluctuations and risk adjustments in computing the Arm's Length Price (ALP) and allowed the appeal partly for statistical purposes. Case-Laws Income Tax Wed, 16 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186271