https://www.taxtmi.com/caselaws?id=311656 The HC ruled that the TNMM method was more appropriate than the CUP method for determining the ALP, emphasizing the importance of functional similarity over transactional similarity. It questioned the comparability of certain companies chosen for benchmarking analysis and stressed the need to satisfy comparability tests under Rule 10B(2). Additionally, the court scrutinized the TPO's addition related to intra-group services, highlighting the necessity of evaluating the economic and commercial value of such services. The judgment underscores the need for factual accuracy and economic relevance in transfer pricing assessments. en-us Mon, 09 Apr 2018 00:00:00 +0530 Sun, 07 Jan 2024 21:01:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311656 The HC ruled that the TNMM method was more appropriate than the CUP method for determining the ALP, emphasizing the importance of functional similarity over transactional similarity. It questioned the comparability of certain companies chosen for benchmarking analysis and stressed the need to satisfy comparability tests under Rule 10B(2). Additionally, the court scrutinized the TPO's addition related to intra-group services, highlighting the necessity of evaluating the economic and commercial value of such services. The judgment underscores the need for factual accuracy and economic relevance in transfer pricing assessments. Case-Laws Income Tax Mon, 09 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311656