https://www.taxtmi.com/caselaws?id=189346 The tribunal allowed the assessee's appeal, accepting the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM) for determining the Arm's Length Price (ALP) of international transactions. It dismissed the revenue's appeal, emphasizing the importance of viewing interlinked transactions as a whole and rejecting speculative conclusions by the Transfer Pricing Officer (TPO). The decision highlighted the need for consistency in transfer pricing methods and substantial evidence to support adjustments. en-us Fri, 04 Dec 2015 00:00:00 +0530 Fri, 06 Jan 2017 13:30:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189346 The tribunal allowed the assessee's appeal, accepting the Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM) for determining the Arm's Length Price (ALP) of international transactions. It dismissed the revenue's appeal, emphasizing the importance of viewing interlinked transactions as a whole and rejecting speculative conclusions by the Transfer Pricing Officer (TPO). The decision highlighted the need for consistency in transfer pricing methods and substantial evidence to support adjustments. Case-Laws Income Tax Fri, 04 Dec 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189346