https://www.taxtmi.com/caselaws?id=334184 The Tribunal upheld the CIT(A)'s decision, affirming that the AO's use of both TNMM and the profit split method was unsustainable. The Tribunal agreed with the CIT(A) that the average margin of 5.84% from the comparables provided by the assessee was appropriate for determining the arm's length price, leading to an adjustment of Rs. 54,37,717/-. The department's appeal was dismissed, confirming that the transactions between the PE and HO were at arm's length, and no additional profit attribution was required. en-us Mon, 12 Sep 2016 00:00:00 +0530 Sat, 05 Nov 2016 07:20:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=334184 The Tribunal upheld the CIT(A)'s decision, affirming that the AO's use of both TNMM and the profit split method was unsustainable. The Tribunal agreed with the CIT(A) that the average margin of 5.84% from the comparables provided by the assessee was appropriate for determining the arm's length price, leading to an adjustment of Rs. 54,37,717/-. The department's appeal was dismissed, confirming that the transactions between the PE and HO were at arm's length, and no additional profit attribution was required. Case-Laws Income Tax Mon, 12 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=334184