https://www.taxtmi.com/caselaws?id=288004 The Tribunal allowed the appeal for statistical purposes, emphasizing the need for a comprehensive review based on its directions. It held that the appellant's Transactional Net Margin Method (TNMM) approach was acceptable and criticized the Transfer Pricing Officer's unilateral shift to the Comparable Uncontrolled Price (CUP) method without valid reasons. The Tribunal emphasized the impermissibility of the benefit test and the intricately connected nature of royalty and product development fees to production and sales, warranting evaluation under TNMM. The previous order was set aside, and the issue was remanded to the TPO for fresh consideration, ensuring a fair opportunity for the appellant. en-us Tue, 30 Jul 2019 00:00:00 +0530 Thu, 14 May 2020 02:08:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=288004 The Tribunal allowed the appeal for statistical purposes, emphasizing the need for a comprehensive review based on its directions. It held that the appellant's Transactional Net Margin Method (TNMM) approach was acceptable and criticized the Transfer Pricing Officer's unilateral shift to the Comparable Uncontrolled Price (CUP) method without valid reasons. The Tribunal emphasized the impermissibility of the benefit test and the intricately connected nature of royalty and product development fees to production and sales, warranting evaluation under TNMM. The previous order was set aside, and the issue was remanded to the TPO for fresh consideration, ensuring a fair opportunity for the appellant. Case-Laws Income Tax Tue, 30 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=288004