https://www.taxtmi.com/caselaws?id=378861 The Tribunal partly allowed the appeals, setting aside the impugned orders and directing the A.O. to re-compute adjustments in line with the provided directions. The main contention was the choice of benchmarking method, with the Tribunal favoring the Transaction Net Margin Method (TNMM) over the Cost Plus Method (CPM). The Tribunal emphasized the need for accurate benchmarking and considerations for surplus revenue/profit set offs in transfer pricing assessments. Penalty proceedings under Section 271(1)(c) were dismissed as premature, focusing primarily on transfer pricing adjustments and methodological discrepancies. en-us Tue, 16 Apr 2019 00:00:00 +0530 Mon, 22 Apr 2019 18:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=378861 The Tribunal partly allowed the appeals, setting aside the impugned orders and directing the A.O. to re-compute adjustments in line with the provided directions. The main contention was the choice of benchmarking method, with the Tribunal favoring the Transaction Net Margin Method (TNMM) over the Cost Plus Method (CPM). The Tribunal emphasized the need for accurate benchmarking and considerations for surplus revenue/profit set offs in transfer pricing assessments. Penalty proceedings under Section 271(1)(c) were dismissed as premature, focusing primarily on transfer pricing adjustments and methodological discrepancies. Case-Laws Income Tax Tue, 16 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=378861