https://www.taxtmi.com/caselaws?id=386812 The Revenue's appeals were dismissed, and the taxpayer's cross objections were deemed infructuous. The CIT(A)'s decision was upheld, confirming the Transaction Net Margin Method (TNMM) as the appropriate method for determining the Arm's Length Price (ALP) at the entity level. The Transfer Pricing Officer's determination of ALP for royalty payments at Rs. NIL was found unjustified, leading to the deletion of adjustments. The taxpayer prevailed on both merits and tax effect for the relevant assessment years. en-us Fri, 04 Oct 2019 00:00:00 +0530 Wed, 09 Oct 2019 07:34:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386812 The Revenue's appeals were dismissed, and the taxpayer's cross objections were deemed infructuous. The CIT(A)'s decision was upheld, confirming the Transaction Net Margin Method (TNMM) as the appropriate method for determining the Arm's Length Price (ALP) at the entity level. The Transfer Pricing Officer's determination of ALP for royalty payments at Rs. NIL was found unjustified, leading to the deletion of adjustments. The taxpayer prevailed on both merits and tax effect for the relevant assessment years. Case-Laws Income Tax Fri, 04 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386812