https://www.taxtmi.com/caselaws?id=350708 The High Court affirmed the ITAT's decision regarding transfer pricing issues. It upheld the use of the Transaction Net Margin Method (TNMM) due to the nature of the assessee's functions. The Court rejected the Resale Price Method (RPM) selected by the TPO, emphasizing functional congruence. It deemed the comparison of profit margins in different segments flawed and disagreed with the TPO's adjustment of intercompany transfer prices. The Court concluded that no substantial legal question arose, dismissing the appeal and supporting the ITAT's detailed analysis on transfer pricing methodologies. en-us Tue, 07 Nov 2017 00:00:00 +0530 Wed, 13 Dec 2017 10:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=350708 The High Court affirmed the ITAT's decision regarding transfer pricing issues. It upheld the use of the Transaction Net Margin Method (TNMM) due to the nature of the assessee's functions. The Court rejected the Resale Price Method (RPM) selected by the TPO, emphasizing functional congruence. It deemed the comparison of profit margins in different segments flawed and disagreed with the TPO's adjustment of intercompany transfer prices. The Court concluded that no substantial legal question arose, dismissing the appeal and supporting the ITAT's detailed analysis on transfer pricing methodologies. Case-Laws Income Tax Tue, 07 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=350708