https://www.taxtmi.com/caselaws?id=413553 Inter-linked international transactions connected with sub-license fee, procurement services, consultancy for a new manufacturing facility, and use of the EASY supply portal were treated as closely integrated with the assessee's manufacturing and trading operations. The isolated benchmarking of those transactions under the Comparable Uncontrolled Price method was found unjustified on the facts, and the proper approach was to consider aggregation and determine the most appropriate method afresh. The transfer pricing exercise was also noted to have suffered from faulty comparables and inadequate consideration of the assessee's objections. Aggregation under TNMM was accepted, and the matter was restored to the Transfer Pricing Officer for fresh computation and reconsideration. en-us Fri, 24 Sep 2021 00:00:00 +0530 Thu, 14 Oct 2021 09:14:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413553 Inter-linked international transactions connected with sub-license fee, procurement services, consultancy for a new manufacturing facility, and use of the EASY supply portal were treated as closely integrated with the assessee's manufacturing and trading operations. The isolated benchmarking of those transactions under the Comparable Uncontrolled Price method was found unjustified on the facts, and the proper approach was to consider aggregation and determine the most appropriate method afresh. The transfer pricing exercise was also noted to have suffered from faulty comparables and inadequate consideration of the assessee's objections. Aggregation under TNMM was accepted, and the matter was restored to the Transfer Pricing Officer for fresh computation and reconsideration. Case-Laws Income Tax Fri, 24 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413553