https://www.taxtmi.com/caselaws?id=405948 The Tribunal remitted the case back to the Transfer Pricing Officer for reconsideration on the benchmarking method for international transactions in the manufacturing segment. It emphasized the principle of consistency in assessment practices and ruled in favor of the taxpayer, directing a review of the Transactional Net Margin Method application and accepting the taxpayer's "other method" based on gross margin comparison with comparable companies. The Tribunal's decision highlighted the importance of maintaining consistency in assessing each year independently when there are no material changes in the taxpayer's business model. en-us Thu, 01 Apr 2021 00:00:00 +0530 Fri, 02 Apr 2021 09:14:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405948 The Tribunal remitted the case back to the Transfer Pricing Officer for reconsideration on the benchmarking method for international transactions in the manufacturing segment. It emphasized the principle of consistency in assessment practices and ruled in favor of the taxpayer, directing a review of the Transactional Net Margin Method application and accepting the taxpayer's "other method" based on gross margin comparison with comparable companies. The Tribunal's decision highlighted the importance of maintaining consistency in assessing each year independently when there are no material changes in the taxpayer's business model. Case-Laws Income Tax Thu, 01 Apr 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405948