https://www.taxtmi.com/caselaws?id=291463 The Tribunal upheld the Dispute Resolution Panel's findings, determining that the Transactional Net Margin Method (TNMM) is the most appropriate method for establishing the Arm's Length Price (ALP) of international transactions. The Tribunal dismissed the revenue's appeal against the deletion of Transfer Pricing (TP) adjustment and the assessee's cross objections, emphasizing the importance of accurate adjustments and comparability in transfer pricing analysis. This decision favored TNMM over the internal Comparable Uncontrolled Price (CUP) method due to significant differences in the transactions compared by the Transfer Pricing Officer. en-us Wed, 28 Oct 2015 00:00:00 +0530 Wed, 11 Nov 2020 19:44:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=291463 The Tribunal upheld the Dispute Resolution Panel's findings, determining that the Transactional Net Margin Method (TNMM) is the most appropriate method for establishing the Arm's Length Price (ALP) of international transactions. The Tribunal dismissed the revenue's appeal against the deletion of Transfer Pricing (TP) adjustment and the assessee's cross objections, emphasizing the importance of accurate adjustments and comparability in transfer pricing analysis. This decision favored TNMM over the internal Comparable Uncontrolled Price (CUP) method due to significant differences in the transactions compared by the Transfer Pricing Officer. Case-Laws Income Tax Wed, 28 Oct 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=291463