https://www.taxtmi.com/caselaws?id=436429 The Tribunal allowed the appeal for Assessment Year 2017-18, challenging the ALP adjustment in international transactions with overseas Associated Enterprises related to the manufacturing segment. The Tribunal upheld the use of internal comparables and the TNMM method for determining the ALP, consistent with previous decisions. Subsequent appeals for TP adjustments and corporate cost allocation disallowance were also allowed based on judicial consistency in decision-making. The Tribunal directed the TPO to compute the ALP for import transactions using internal comparables, following Gemstone Glass (P.) Ltd. vs. JCIT, with the appeal partly allowed for statistical purposes. en-us Fri, 30 Dec 2022 00:00:00 +0530 Fri, 20 Feb 2026 17:21:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436429 The Tribunal allowed the appeal for Assessment Year 2017-18, challenging the ALP adjustment in international transactions with overseas Associated Enterprises related to the manufacturing segment. The Tribunal upheld the use of internal comparables and the TNMM method for determining the ALP, consistent with previous decisions. Subsequent appeals for TP adjustments and corporate cost allocation disallowance were also allowed based on judicial consistency in decision-making. The Tribunal directed the TPO to compute the ALP for import transactions using internal comparables, following Gemstone Glass (P.) Ltd. vs. JCIT, with the appeal partly allowed for statistical purposes. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436429