https://www.taxtmi.com/caselaws?id=399445 The Tribunal held that the Comparable Uncontrolled Price (CUP) method was more appropriate than the Transactional Net Margin Method (TNMM) for Transfer Pricing Adjustments under the Income Tax Act. It emphasized the importance of internal comparables for justifying the CUP method, noted insignificant geographical market differences, and upheld the Transfer Pricing Officer's jurisdiction to question commercial expediency. The Tribunal disallowed commission expenditure due to lack of evidence of services rendered. The case was remanded for recalculating arm's length price and reassessing commission expenditure. en-us Wed, 30 Sep 2020 00:00:00 +0530 Sat, 10 Oct 2020 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=399445 The Tribunal held that the Comparable Uncontrolled Price (CUP) method was more appropriate than the Transactional Net Margin Method (TNMM) for Transfer Pricing Adjustments under the Income Tax Act. It emphasized the importance of internal comparables for justifying the CUP method, noted insignificant geographical market differences, and upheld the Transfer Pricing Officer's jurisdiction to question commercial expediency. The Tribunal disallowed commission expenditure due to lack of evidence of services rendered. The case was remanded for recalculating arm's length price and reassessing commission expenditure. Case-Laws Income Tax Wed, 30 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=399445