https://www.taxtmi.com/caselaws?id=288026 The taxpayer's appeal was allowed for statistical purposes, and various issues were remanded to the Transfer Pricing Officer (TPO) for reconsideration. The Tribunal found the TPO's rejection of TNMM for benchmarking royalty payments as inappropriate, emphasizing the need for consistency and proper reasoning in transfer pricing decisions. The TPO was directed to reassess the comparables and capacity utilization adjustment, stressing the importance of providing the taxpayer an opportunity to be heard in the process. en-us Fri, 16 Nov 2018 00:00:00 +0530 Thu, 14 May 2020 13:26:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=288026 The taxpayer's appeal was allowed for statistical purposes, and various issues were remanded to the Transfer Pricing Officer (TPO) for reconsideration. The Tribunal found the TPO's rejection of TNMM for benchmarking royalty payments as inappropriate, emphasizing the need for consistency and proper reasoning in transfer pricing decisions. The TPO was directed to reassess the comparables and capacity utilization adjustment, stressing the importance of providing the taxpayer an opportunity to be heard in the process. Case-Laws Income Tax Fri, 16 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=288026