https://www.taxtmi.com/caselaws?id=307191 The Tribunal allowed the assessee's appeal in full, directing the deletion of transfer pricing adjustments and permitting the claim for additional depreciation on tooling. The Tribunal emphasized consistency with past decisions and the preference for the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method for determining the Arm's Length Price (ALP) in international transactions. The decision highlighted that the TNMM was deemed more appropriate, overturning the Transfer Pricing Officer's application of the CUP method, ultimately leading to the allowance of the appeal. en-us Thu, 02 May 2019 00:00:00 +0530 Fri, 24 Mar 2023 19:37:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307191 The Tribunal allowed the assessee's appeal in full, directing the deletion of transfer pricing adjustments and permitting the claim for additional depreciation on tooling. The Tribunal emphasized consistency with past decisions and the preference for the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method for determining the Arm's Length Price (ALP) in international transactions. The decision highlighted that the TNMM was deemed more appropriate, overturning the Transfer Pricing Officer's application of the CUP method, ultimately leading to the allowance of the appeal. Case-Laws Income Tax Thu, 02 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307191