https://www.taxtmi.com/caselaws?id=189852 The High Court of Bombay dismissed the appeal challenging the Income Tax Appellate Tribunal's order for Assessment Year 2005-06. The Court upheld the Tribunal's decision on transfer pricing, confirming the use of the Transaction Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method. The Court emphasized the importance of considering export benefits in turnover for accurate comparison and found no need for Transfer Pricing adjustment as profit margin variances were within the safe harbor limit. The appeal was ultimately rejected, with the Court affirming the Tribunal's order and dismissing the Revenue's contentions. en-us Tue, 22 Sep 2015 00:00:00 +0530 Mon, 23 Jan 2017 17:46:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189852 The High Court of Bombay dismissed the appeal challenging the Income Tax Appellate Tribunal's order for Assessment Year 2005-06. The Court upheld the Tribunal's decision on transfer pricing, confirming the use of the Transaction Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method. The Court emphasized the importance of considering export benefits in turnover for accurate comparison and found no need for Transfer Pricing adjustment as profit margin variances were within the safe harbor limit. The appeal was ultimately rejected, with the Court affirming the Tribunal's order and dismissing the Revenue's contentions. Case-Laws Income Tax Tue, 22 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189852