https://www.taxtmi.com/caselaws?id=307595 The Tribunal directed the matter back to the AO/TPO to benchmark international transactions using TNMM with Berry ratio as PLI. The assessee must substantiate margins with comparable uncontrolled transactions, emphasizing adherence to TNMM and consistency, rejecting protective adjustments and the CUP method. The appeal was allowed for statistical purposes, with the AO/TPO to decide based on facts and law, ensuring due process and hearing for the assessee. en-us Tue, 03 Nov 2020 00:00:00 +0530 Mon, 24 Apr 2023 21:07:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307595 The Tribunal directed the matter back to the AO/TPO to benchmark international transactions using TNMM with Berry ratio as PLI. The assessee must substantiate margins with comparable uncontrolled transactions, emphasizing adherence to TNMM and consistency, rejecting protective adjustments and the CUP method. The appeal was allowed for statistical purposes, with the AO/TPO to decide based on facts and law, ensuring due process and hearing for the assessee. Case-Laws Income Tax Tue, 03 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307595