https://www.taxtmi.com/caselaws?id=470195 Transfer-pricing method selection must reflect the taxpayer's segmental allocation of revenue and costs, product comparability, and functions, assets and risks (FAR) profile. CUP, RPM or CPM should be preferred where they can reliably determine the arm's length price, while TNMM applies where traditional transaction methods are unsuitable. A taxpayer may seek a prescribed method different from that used in its transfer-pricing report if it provides a more appropriate arm's length result. Where TNMM is used, adjustments may be considered for established material differences with comparables. The transfer-pricing analysis requires fresh verification on these parameters. en-us Mon, 17 Mar 2025 00:00:00 +0530 Sat, 18 Jul 2026 21:09:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470195 Transfer-pricing method selection must reflect the taxpayer's segmental allocation of revenue and costs, product comparability, and functions, assets and risks (FAR) profile. CUP, RPM or CPM should be preferred where they can reliably determine the arm's length price, while TNMM applies where traditional transaction methods are unsuitable. A taxpayer may seek a prescribed method different from that used in its transfer-pricing report if it provides a more appropriate arm's length result. Where TNMM is used, adjustments may be considered for established material differences with comparables. The transfer-pricing analysis requires fresh verification on these parameters. Case-Laws Income Tax Mon, 17 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470195