https://www.taxtmi.com/caselaws?id=296371 The Tribunal rejected the application of Transaction Net Marginal method (TNMM), Cost Plus method (CPM), and Comparable Uncontrolled Price (CUP) method for determining the Arm's Length Price (ALP) of international Management Fees transactions due to incorrect application. The Tribunal emphasized the importance of selecting and applying the method correctly. The matter was remanded to the Transfer Pricing Officer (TPO) for fresh determination, granting discretion to choose the appropriate method based on circumstances. The Tribunal dismissed the request to direct a specific method selection, allowing flexibility for the TPO in determining the ALP. en-us Mon, 18 Jan 2021 00:00:00 +0530 Sat, 17 Jul 2021 07:26:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296371 The Tribunal rejected the application of Transaction Net Marginal method (TNMM), Cost Plus method (CPM), and Comparable Uncontrolled Price (CUP) method for determining the Arm's Length Price (ALP) of international Management Fees transactions due to incorrect application. The Tribunal emphasized the importance of selecting and applying the method correctly. The matter was remanded to the Transfer Pricing Officer (TPO) for fresh determination, granting discretion to choose the appropriate method based on circumstances. The Tribunal dismissed the request to direct a specific method selection, allowing flexibility for the TPO in determining the ALP. Case-Laws Income Tax Mon, 18 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296371