https://www.taxtmi.com/caselaws?id=431453 The Tribunal ruled in favor of the assessee, directing the deletion of transfer pricing adjustments made using the Comparable Uncontrolled Price (CUP) method for international transactions with associated enterprises. The Tribunal found that applying two different methods for the same class of transactions and selectively adjusting transactions was incorrect. It held that the Transactional Net Margin Method (TNMM) was the appropriate benchmarking method for the majority of transactions, and the CUP method was not justified for the minimal portion of transactions. The appeals for different assessment years were allowed, emphasizing consistency in applying transfer pricing methods. en-us Fri, 12 Aug 2022 00:00:00 +0530 Tue, 13 Dec 2022 11:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=431453 The Tribunal ruled in favor of the assessee, directing the deletion of transfer pricing adjustments made using the Comparable Uncontrolled Price (CUP) method for international transactions with associated enterprises. The Tribunal found that applying two different methods for the same class of transactions and selectively adjusting transactions was incorrect. It held that the Transactional Net Margin Method (TNMM) was the appropriate benchmarking method for the majority of transactions, and the CUP method was not justified for the minimal portion of transactions. The appeals for different assessment years were allowed, emphasizing consistency in applying transfer pricing methods. Case-Laws Income Tax Fri, 12 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=431453