https://www.taxtmi.com/caselaws?id=363426 The Tribunal directed the AO to adopt the Comparable Uncontrolled Price (CUP) method for benchmarking international transactions, overturning the Transactional Net Margin Method (TNMM) adjustment. The appeal was allowed for statistical purposes, emphasizing the use of CUP as consistently done in subsequent years. The Tribunal highlighted the acceptance of the Resale Price Method (RPM) by the Transfer Pricing Officer in later years, supporting the assessee's argument for RPM application based on OECD guidelines. The decision was rendered on 04-07-2018. en-us Wed, 04 Jul 2018 00:00:00 +0530 Thu, 12 Jul 2018 08:33:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=363426 The Tribunal directed the AO to adopt the Comparable Uncontrolled Price (CUP) method for benchmarking international transactions, overturning the Transactional Net Margin Method (TNMM) adjustment. The appeal was allowed for statistical purposes, emphasizing the use of CUP as consistently done in subsequent years. The Tribunal highlighted the acceptance of the Resale Price Method (RPM) by the Transfer Pricing Officer in later years, supporting the assessee's argument for RPM application based on OECD guidelines. The decision was rendered on 04-07-2018. Case-Laws Income Tax Wed, 04 Jul 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=363426