https://www.taxtmi.com/caselaws?id=312676 The ITAT Bangalore set aside the ALP determination and remanded the matter to the TPO for fresh assessment. The tribunal directed application of TNMM as the most appropriate method for determining arm's length price of international transactions with AEs, following precedent from assessee's own case for AY 2013-14. The court rejected PSM application, finding the assessee made no unique contribution to the transaction. The appeal was allowed for statistical purposes with directions for reasonable opportunity of hearing. en-us Thu, 02 Jun 2022 00:00:00 +0530 Wed, 13 Mar 2024 12:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312676 The ITAT Bangalore set aside the ALP determination and remanded the matter to the TPO for fresh assessment. The tribunal directed application of TNMM as the most appropriate method for determining arm's length price of international transactions with AEs, following precedent from assessee's own case for AY 2013-14. The court rejected PSM application, finding the assessee made no unique contribution to the transaction. The appeal was allowed for statistical purposes with directions for reasonable opportunity of hearing. Case-Laws Income Tax Thu, 02 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312676