https://www.taxtmi.com/caselaws?id=280371 The Tribunal allowed the assessee's appeal and dismissed the revenue's appeal, upholding the use of the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method for transfer pricing adjustments. The Tribunal emphasized the need for accurate adjustments for differences between associated enterprise (AE) and non-AE transactions. Additionally, the Tribunal allowed the research and development expenditure claim, recognized amortized expenses as revenue expenditure, and directed the deletion of disallowed expenses, ultimately granting relief to the assessee. en-us Tue, 12 Feb 2019 00:00:00 +0530 Thu, 02 May 2019 07:39:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=280371 The Tribunal allowed the assessee's appeal and dismissed the revenue's appeal, upholding the use of the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method for transfer pricing adjustments. The Tribunal emphasized the need for accurate adjustments for differences between associated enterprise (AE) and non-AE transactions. Additionally, the Tribunal allowed the research and development expenditure claim, recognized amortized expenses as revenue expenditure, and directed the deletion of disallowed expenses, ultimately granting relief to the assessee. Case-Laws Income Tax Tue, 12 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=280371