https://www.taxtmi.com/caselaws?id=447891 Transfer-pricing issues concerning bogie and wagon supplies were sent back for fresh appellate consideration, as the alleged price recovery between the assessee and its associated enterprise was treated as a factual matter requiring review of the existing record. The selection of comparables for benchmarking arm's length price was also remitted to the Commissioner of Income Tax (Appeals) for reconsideration. On the method question, the earlier position favouring Transactional Net Margin Method for the relevant year was preserved unless distinguishing facts for that year were shown; automatic substitution of Comparable Uncontrolled Price Method was not accepted as a free-standing proposition. en-us Mon, 18 Dec 2023 00:00:00 +0530 Mon, 08 Jan 2024 09:13:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447891 Transfer-pricing issues concerning bogie and wagon supplies were sent back for fresh appellate consideration, as the alleged price recovery between the assessee and its associated enterprise was treated as a factual matter requiring review of the existing record. The selection of comparables for benchmarking arm's length price was also remitted to the Commissioner of Income Tax (Appeals) for reconsideration. On the method question, the earlier position favouring Transactional Net Margin Method for the relevant year was preserved unless distinguishing facts for that year were shown; automatic substitution of Comparable Uncontrolled Price Method was not accepted as a free-standing proposition. Case-Laws Income Tax Mon, 18 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447891