https://www.taxtmi.com/caselaws?id=306276 The Tribunal dismissed the Revenue's appeals for assessment years 2011-12 and 2012-13, upholding the use of the Transactional Net Margin Method (TNMM) for determining Arm's Length Price (ALP) of international transactions. The Tribunal found that the TNMM was appropriate due to the lack of comparables and nature of transactions, rejecting the Revenue's contention to apply the Comparable Uncontrolled Price (CUP) method. The decision was based on consistent findings of the CIT(A) and prior Tribunal and High Court rulings in favor of the appellant, leading to the dismissal of the Revenue's appeals. en-us Fri, 07 Aug 2020 00:00:00 +0530 Fri, 20 Jan 2023 07:16:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306276 The Tribunal dismissed the Revenue's appeals for assessment years 2011-12 and 2012-13, upholding the use of the Transactional Net Margin Method (TNMM) for determining Arm's Length Price (ALP) of international transactions. The Tribunal found that the TNMM was appropriate due to the lack of comparables and nature of transactions, rejecting the Revenue's contention to apply the Comparable Uncontrolled Price (CUP) method. The decision was based on consistent findings of the CIT(A) and prior Tribunal and High Court rulings in favor of the appellant, leading to the dismissal of the Revenue's appeals. Case-Laws Income Tax Fri, 07 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306276