https://www.taxtmi.com/caselaws?id=413825 The Tribunal held that the Comparable Uncontrolled Price (CUP) method was not appropriate due to lack of comparable uncontrolled transactions in India and geographical differences. The Transfer Pricing Officer's (TPO) application of the Transactional Net Margin Method (TNMM) was upheld but directed that transfer pricing adjustments should be limited to international transactions only, following established case law. The matter was remanded to the TPO for re-determining the Arm's Length Price (ALP) using TNMM with adjustments restricted to international transactions. The appeal was partly allowed for statistical purposes. en-us Wed, 13 Oct 2021 00:00:00 +0530 Thu, 21 Oct 2021 08:18:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413825 The Tribunal held that the Comparable Uncontrolled Price (CUP) method was not appropriate due to lack of comparable uncontrolled transactions in India and geographical differences. The Transfer Pricing Officer's (TPO) application of the Transactional Net Margin Method (TNMM) was upheld but directed that transfer pricing adjustments should be limited to international transactions only, following established case law. The matter was remanded to the TPO for re-determining the Arm's Length Price (ALP) using TNMM with adjustments restricted to international transactions. The appeal was partly allowed for statistical purposes. Case-Laws Income Tax Wed, 13 Oct 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413825