https://www.taxtmi.com/highlights?id=102883 Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law. en-us Thu, 20 Aug 2026 08:14:28 +0530 Thu, 20 Aug 2026 08:14:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102883 Transfer-pricing method selection between the Comparable Uncontrolled Price method and the Transactional Net Margin Method is primarily a fact-based benchmarking issue. The Tribunal's acceptance of TNMM as the most appropriate method was treated as sustainable where it was not perverse or contrary to the record. Mere disagreement over the appropriate method does not create a substantial question of law under section 260A unless the selected method contravenes prescribed rules. Differences between associated-enterprise and non-associated-enterprise transactions were also considered within the benchmarking analysis. The tax appeals were dismissed because the transfer-pricing questions raised no substantial question of law. Highlights Income Tax Thu, 20 Aug 2026 08:14:28 +0530 https://www.taxtmi.com/highlights?id=102883