https://www.taxtmi.com/caselaws?id=281678 The Appellate Tribunal ruled in cross appeals for A.Y 2011-12, overturning the CIT (A)'s decision on transfer pricing method. It found the CUP method inappropriate due to significant differences between the assessee and comparables, emphasizing the need for the most suitable method based on similarities. The TNMM method was deemed more appropriate, leading to remand of ALP determination to the AO. The Revenue's appeals were dismissed, the assessee's appeal allowed for statistical purposes, and the Revenue's appeal rendered infructuous. The decision underscores the importance of a meticulous approach in transfer pricing for fair ALP determination. en-us Wed, 30 Nov 2016 00:00:00 +0530 Mon, 01 Jul 2019 07:25:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281678 The Appellate Tribunal ruled in cross appeals for A.Y 2011-12, overturning the CIT (A)'s decision on transfer pricing method. It found the CUP method inappropriate due to significant differences between the assessee and comparables, emphasizing the need for the most suitable method based on similarities. The TNMM method was deemed more appropriate, leading to remand of ALP determination to the AO. The Revenue's appeals were dismissed, the assessee's appeal allowed for statistical purposes, and the Revenue's appeal rendered infructuous. The decision underscores the importance of a meticulous approach in transfer pricing for fair ALP determination. Case-Laws Income Tax Wed, 30 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281678