https://www.taxtmi.com/caselaws?id=344311 Additional evidence was accepted under Rule 46A because the assessee had not been given adequate time before the transfer pricing authority, the material was relevant, reasons were recorded, and the revenue had full remand opportunity. In transfer pricing, Berry Ratio was held inapplicable where the associated enterprise carried on an independent chartering business, assumed entrepreneurial risk, and was not a pure distributor; TNMM with operating profit to total cost was accepted as the proper method. Only controlled transactions between the assessee and the associated enterprise could be used for arm's length analysis, not the associated enterprise's third-party dealings. An ad hoc office expense disallowance based on estimate was deleted because no specific unverifiable item was identified. en-us Wed, 01 Mar 2017 00:00:00 +0530 Wed, 14 Jun 2017 14:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344311 Additional evidence was accepted under Rule 46A because the assessee had not been given adequate time before the transfer pricing authority, the material was relevant, reasons were recorded, and the revenue had full remand opportunity. In transfer pricing, Berry Ratio was held inapplicable where the associated enterprise carried on an independent chartering business, assumed entrepreneurial risk, and was not a pure distributor; TNMM with operating profit to total cost was accepted as the proper method. Only controlled transactions between the assessee and the associated enterprise could be used for arm's length analysis, not the associated enterprise's third-party dealings. An ad hoc office expense disallowance based on estimate was deleted because no specific unverifiable item was identified. Case-Laws Income Tax Wed, 01 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344311