https://www.taxtmi.com/caselaws?id=286700 The Tribunal found in favor of the assessee, highlighting errors by the AO and TPO in benchmarking support services and determining the arm's length price. It emphasized the use of the Transaction Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method. The Tribunal directed a reassessment, considering documentary evidence and attributing support services correctly. It also criticized the initiation of penalty proceedings under Section 271(1)(c) and instructed the AO to rectify tax computation errors. The appeal was allowed for statistical purposes, stressing the importance of a thorough review and adherence to appropriate transfer pricing methods. en-us Thu, 30 Mar 2017 00:00:00 +0530 Thu, 12 Mar 2020 07:15:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286700 The Tribunal found in favor of the assessee, highlighting errors by the AO and TPO in benchmarking support services and determining the arm's length price. It emphasized the use of the Transaction Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method. The Tribunal directed a reassessment, considering documentary evidence and attributing support services correctly. It also criticized the initiation of penalty proceedings under Section 271(1)(c) and instructed the AO to rectify tax computation errors. The appeal was allowed for statistical purposes, stressing the importance of a thorough review and adherence to appropriate transfer pricing methods. Case-Laws Income Tax Thu, 30 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286700