https://www.taxtmi.com/caselaws?id=433203 The Tribunal allowed the appeal for statistical purposes, directing a re-consideration of the Transfer Pricing adjustments based on the internal Comparable Uncontrolled Price (CUP) method for the assessment year 2011-12. The Tribunal emphasized the need for the assessee to justify the initial selection of the Transactional Net Margin Method (TNMM) over the CUP method, especially in light of subsequent developments favoring the latter method for the assessment year 2012-13. The case highlighted the importance of consistency and justification in selecting the most appropriate method for determining the Arm's Length Price (ALP) of international transactions with Associate Enterprises (AE). en-us Fri, 04 Nov 2022 00:00:00 +0530 Tue, 24 Jan 2023 10:11:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433203 The Tribunal allowed the appeal for statistical purposes, directing a re-consideration of the Transfer Pricing adjustments based on the internal Comparable Uncontrolled Price (CUP) method for the assessment year 2011-12. The Tribunal emphasized the need for the assessee to justify the initial selection of the Transactional Net Margin Method (TNMM) over the CUP method, especially in light of subsequent developments favoring the latter method for the assessment year 2012-13. The case highlighted the importance of consistency and justification in selecting the most appropriate method for determining the Arm's Length Price (ALP) of international transactions with Associate Enterprises (AE). Case-Laws Income Tax Fri, 04 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433203