https://www.taxtmi.com/caselaws?id=775603 The ITAT Lucknow held that the assessee's selection of internal TNMM as the Most Appropriate Method (MAM) for specified domestic transactions could not be rejected without cogent reasons. The TPO and SCN failed to provide any justification for discarding the internal TNMM and substituting it with an external TNMM using ten comparables. Since internal TNMM is a recognized method for determining arm's length price, the TPO's rejection was unjustified. Consequently, the transfer pricing adjustment based on the external TNMM was set aside, and the assessee's appeal was allowed. en-us Mon, 30 Jun 2025 00:00:00 +0530 Mon, 28 Jul 2025 08:27:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775603 The ITAT Lucknow held that the assessee's selection of internal TNMM as the Most Appropriate Method (MAM) for specified domestic transactions could not be rejected without cogent reasons. The TPO and SCN failed to provide any justification for discarding the internal TNMM and substituting it with an external TNMM using ten comparables. Since internal TNMM is a recognized method for determining arm's length price, the TPO's rejection was unjustified. Consequently, the transfer pricing adjustment based on the external TNMM was set aside, and the assessee's appeal was allowed. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775603