https://www.taxtmi.com/caselaws?id=443066 The Tribunal partially allowed the Revenue's appeal and dismissed the assessee's Cross Objection, remitting the matter to the AO/TPO for fresh determination of the ALP of the international transactions, ensuring the assessee is given a reasonable opportunity of hearing. The Tribunal favored the TPO's Sales ratio method over the Gross Profit ratio for cost allocation between 'Trading' and 'Manufacturing' segments. Additionally, the Tribunal overturned the CIT(A)'s decision on the adjustment towards higher custom duty paid, computation of working capital adjustment, and application of the Comparable Uncontrolled Price (CUP) method, upholding the TNMM as the appropriate method for the international transaction of 'Sale of finished goods.' en-us Wed, 13 Sep 2023 00:00:00 +0530 Fri, 15 Sep 2023 08:54:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443066 The Tribunal partially allowed the Revenue's appeal and dismissed the assessee's Cross Objection, remitting the matter to the AO/TPO for fresh determination of the ALP of the international transactions, ensuring the assessee is given a reasonable opportunity of hearing. The Tribunal favored the TPO's Sales ratio method over the Gross Profit ratio for cost allocation between 'Trading' and 'Manufacturing' segments. Additionally, the Tribunal overturned the CIT(A)'s decision on the adjustment towards higher custom duty paid, computation of working capital adjustment, and application of the Comparable Uncontrolled Price (CUP) method, upholding the TNMM as the appropriate method for the international transaction of 'Sale of finished goods.' Case-Laws Income Tax Wed, 13 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443066