https://www.taxtmi.com/caselaws?id=374186 The Tribunal allowed the appeal filed by the assessee, directing the AO to delete the upward adjustment of Rs. 143,67,42,784 confirmed by the DRP. It held that the TPO's determination of the Arm's Length Price (ALP) on an estimation basis was not sustainable in law and that the Transactional Net Margin Method (TNMM) applied by the assessee was the most appropriate method for benchmarking the international transactions. The Tribunal emphasized that the TPO must follow one of the prescribed methods under section 92C(1) of the Income Tax Act and that ad-hoc determination of the ALP is impermissible. en-us Wed, 16 Jan 2019 00:00:00 +0530 Mon, 28 Jan 2019 07:52:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374186 The Tribunal allowed the appeal filed by the assessee, directing the AO to delete the upward adjustment of Rs. 143,67,42,784 confirmed by the DRP. It held that the TPO's determination of the Arm's Length Price (ALP) on an estimation basis was not sustainable in law and that the Transactional Net Margin Method (TNMM) applied by the assessee was the most appropriate method for benchmarking the international transactions. The Tribunal emphasized that the TPO must follow one of the prescribed methods under section 92C(1) of the Income Tax Act and that ad-hoc determination of the ALP is impermissible. Case-Laws Income Tax Wed, 16 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374186