https://www.taxtmi.com/caselaws?id=339201 The Tribunal set aside the lower authorities' decisions, emphasizing the lack of comparable uncontrolled transactions for benchmarking R&D and management fees. Without identified comparables, the CUP method could not be favored over TNMM. The Tribunal remitted the issue of determining the ALP of international transactions under TNMM back to the Assessing Officer/TPO for reconsideration. The assessee's appeals for all three assessment years were allowed for statistical purposes. en-us Wed, 21 Dec 2016 00:00:00 +0530 Fri, 18 Sep 2026 13:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=339201 The Tribunal set aside the lower authorities' decisions, emphasizing the lack of comparable uncontrolled transactions for benchmarking R&D and management fees. Without identified comparables, the CUP method could not be favored over TNMM. The Tribunal remitted the issue of determining the ALP of international transactions under TNMM back to the Assessing Officer/TPO for reconsideration. The assessee's appeals for all three assessment years were allowed for statistical purposes. Case-Laws Income Tax Wed, 21 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=339201