https://www.taxtmi.com/caselaws?id=336698 The appeal was filed by the Revenue against the deletion of an addition in an international sales transaction. The Assessing Officer and Transfer Pricing Officer recommended an upward adjustment based on the company's loss, using the Cost Plus Method (CPM) instead of the Transactional Net Margin Method (TNMM). However, the Tribunal upheld the deletion, citing the lack of justification for choosing CPM over TNMM and flawed comparisons with other companies. The appeal was dismissed, emphasizing the need for proper justification in transfer pricing assessments. en-us Tue, 26 Jul 2016 00:00:00 +0530 Tue, 27 Dec 2016 19:03:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336698 The appeal was filed by the Revenue against the deletion of an addition in an international sales transaction. The Assessing Officer and Transfer Pricing Officer recommended an upward adjustment based on the company's loss, using the Cost Plus Method (CPM) instead of the Transactional Net Margin Method (TNMM). However, the Tribunal upheld the deletion, citing the lack of justification for choosing CPM over TNMM and flawed comparisons with other companies. The appeal was dismissed, emphasizing the need for proper justification in transfer pricing assessments. Case-Laws Income Tax Tue, 26 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336698