https://www.taxtmi.com/caselaws?id=393652 For applying the Transactional Net Margin Method under Rule 10B(1)(e), the assessee's net profit margin must be computed by reference to the assessee's own costs, assets or sales, and not by importing costs incurred by unrelated third-party vendors or the associated enterprise. The cost base cannot be artificially expanded by adding third-party manufacture or export expenses, and a transfer pricing adjustment cannot be sustained on a notional percentage of FOB value attributable to such transactions. The issue was therefore answered against the Revenue and in favour of the assessee, with no question of law arising for consideration. en-us Thu, 12 Mar 2020 00:00:00 +0530 Fri, 20 Mar 2020 15:08:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393652 For applying the Transactional Net Margin Method under Rule 10B(1)(e), the assessee's net profit margin must be computed by reference to the assessee's own costs, assets or sales, and not by importing costs incurred by unrelated third-party vendors or the associated enterprise. The cost base cannot be artificially expanded by adding third-party manufacture or export expenses, and a transfer pricing adjustment cannot be sustained on a notional percentage of FOB value attributable to such transactions. The issue was therefore answered against the Revenue and in favour of the assessee, with no question of law arising for consideration. Case-Laws Income Tax Thu, 12 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393652