https://www.taxtmi.com/caselaws?id=462956 The transfer pricing framework requires the Transfer Pricing Officer to record cogent reasons before rejecting an assessee's substantiated Most Appropriate Method. Where the assessee supports the Internal Cost Plus Method in its transfer pricing study, the officer cannot discard it and substitute the External Transaction Net Margin Method on an arbitrary or irrational basis. The High Court found no legal infirmity in the Tribunal's view and no substantial question of law arose from its order. en-us Thu, 06 Nov 2014 00:00:00 +0530 Sat, 26 Jul 2025 21:05:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462956 The transfer pricing framework requires the Transfer Pricing Officer to record cogent reasons before rejecting an assessee's substantiated Most Appropriate Method. Where the assessee supports the Internal Cost Plus Method in its transfer pricing study, the officer cannot discard it and substitute the External Transaction Net Margin Method on an arbitrary or irrational basis. The High Court found no legal infirmity in the Tribunal's view and no substantial question of law arose from its order. Case-Laws Income Tax Thu, 06 Nov 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462956