https://www.taxtmi.com/caselaws?id=375822 The Court upheld the consistent application of the Transactional Net Margin Method (TNM Method) by the Revenue for benchmarking international transactions with associated enterprises, emphasizing the importance of factual consistency and lack of material differences to justify a change in transfer pricing methodology. The appeal challenging the use of TNM Method over Resale Price Method (RPM) and Cost Plus Method (CPM) was dismissed due to the absence of substantial legal questions, with the Court emphasizing the Tribunal's factual assessment as the basis for its decision. en-us Mon, 18 Feb 2019 00:00:00 +0530 Tue, 26 Feb 2019 07:23:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375822 The Court upheld the consistent application of the Transactional Net Margin Method (TNM Method) by the Revenue for benchmarking international transactions with associated enterprises, emphasizing the importance of factual consistency and lack of material differences to justify a change in transfer pricing methodology. The appeal challenging the use of TNM Method over Resale Price Method (RPM) and Cost Plus Method (CPM) was dismissed due to the absence of substantial legal questions, with the Court emphasizing the Tribunal's factual assessment as the basis for its decision. Case-Laws Income Tax Mon, 18 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375822