https://www.taxtmi.com/caselaws?id=380712 The Tribunal remanded the case back to the Transfer Pricing Officer (TPO) to re-examine and benchmark international transactions using the Transactional Net Margin Method (TNMM) with Berry ratio as the Profit Level Indicator (PLI). The TPO was directed to provide the appellant with a proper opportunity to substantiate its arm's length price (ALP). The appeals for both assessment years were allowed for statistical purposes, with instructions for the TPO to adhere to the Tribunal's guidance and ensure due process for the appellant. en-us Tue, 21 May 2019 00:00:00 +0530 Mon, 27 May 2019 07:25:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380712 The Tribunal remanded the case back to the Transfer Pricing Officer (TPO) to re-examine and benchmark international transactions using the Transactional Net Margin Method (TNMM) with Berry ratio as the Profit Level Indicator (PLI). The TPO was directed to provide the appellant with a proper opportunity to substantiate its arm's length price (ALP). The appeals for both assessment years were allowed for statistical purposes, with instructions for the TPO to adhere to the Tribunal's guidance and ensure due process for the appellant. Case-Laws Income Tax Tue, 21 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380712