https://www.taxtmi.com/caselaws?id=192251 The dispute concerns selection of transfer pricing method and related adjustments. The tribunal examined rejection of Cost Plus Method in favour of Transactional Net Margin Method by the TPO and directed ALP computation adopting CPM as the appropriate method, resulting in recalculation of the international transaction pricing. The tribunal also held that the Profit Level Indicator must be applied to costs attributable to transactions with the associated enterprise only, limiting adjustments to internal international dealings. Levy of interest on underassessment was reserved pending final income determination, and the Dispute Resolution Panel endorsement was considered in relation to those adjustments. en-us Thu, 22 Aug 2013 00:00:00 +0530 Sat, 24 Jan 2026 11:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192251 The dispute concerns selection of transfer pricing method and related adjustments. The tribunal examined rejection of Cost Plus Method in favour of Transactional Net Margin Method by the TPO and directed ALP computation adopting CPM as the appropriate method, resulting in recalculation of the international transaction pricing. The tribunal also held that the Profit Level Indicator must be applied to costs attributable to transactions with the associated enterprise only, limiting adjustments to internal international dealings. Levy of interest on underassessment was reserved pending final income determination, and the Dispute Resolution Panel endorsement was considered in relation to those adjustments. Case-Laws Income Tax Thu, 22 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192251