DRP's TNMM method for software consultancy transfer pricing reversed; TPO directed to use CUP method instead.

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....TP Adjustment - International transactions with its AEs for providing software consultancy services - Selection of MAM - DRP without appreciating the above facts, has simply upheld TNMM as most appropriate method and upheld the TP adjustment as suggested by the TPO. Hence, we reverse the findings of the DRP and direct the TPO to consider CUP as most appropriate method to bench mark international transactions with its AEs. - AT....