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Assessing Officer's Transfer Pricing Adjustment Overturned for Using Both TNMM and Profit Split Method Simultaneously.
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....Transfer pricing adjustment - the action of the AO was not sustainable because he on the one hand had accepted TNMM and also used profit split method for attribution of profit on the international transaction at 50:50 ratio. - either of the two methods could have been used and not both - AT....
TaxTMI
TaxTMI