https://www.taxtmi.com/caselaws?id=305773 The appellate tribunal allowed the appeal in favor of the assessee regarding the determination of the Arm's Length Price (ALP) of international transactions. It held that the Transfer Pricing Officer (TPO) should have maintained consistency in methodology, as the Cost Plus Method (CPM) had been accepted in preceding and succeeding years. Emphasizing the principle of consistency in tax proceedings, the tribunal overturned the TPO's decision to apply the Transactional Net Margin Method (TNMM) and make an upward adjustment. The appeal was allowed, resulting in the order favoring the assessee on 24th October 2018. en-us Wed, 24 Oct 2018 00:00:00 +0530 Thu, 22 Dec 2022 21:52:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=305773 The appellate tribunal allowed the appeal in favor of the assessee regarding the determination of the Arm's Length Price (ALP) of international transactions. It held that the Transfer Pricing Officer (TPO) should have maintained consistency in methodology, as the Cost Plus Method (CPM) had been accepted in preceding and succeeding years. Emphasizing the principle of consistency in tax proceedings, the tribunal overturned the TPO's decision to apply the Transactional Net Margin Method (TNMM) and make an upward adjustment. The appeal was allowed, resulting in the order favoring the assessee on 24th October 2018. Case-Laws Income Tax Wed, 24 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=305773