ITAT adjudicated a transfer pricing dispute involving ...

Multinational Firms Win Transfer Pricing Battle: TNMM Method Validated, Interconnected Transactions Recognized as Single Economic Unit

April 16, 2025

Case Laws Income Tax AT

ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal found that tax authorities erroneously rejected the Transactional Net Margin Method (TNMM) for determining arm's length pricing. The ITAT held that the disputed transactions were intrinsically linked and should be aggregated, with the assessee's calculated margins of 16.99% being acceptable. The tribunal criticized the tax authorities for arbitrarily segregating transactions without substantive evidence or comparability tests. The decision affirmed that interconnected transactions related to a single product line can be evaluated holistically. Consequently, the ITAT ruled in favor of the assessee, setting aside the transfer pricing adjustments and rejecting the tax department's separate transaction assessment approach.

View Source

← Previous Next →

ITAT adjudicated a transfer pricing dispute involving ...

Multinational Firms Win Transfer Pricing Battle: TNMM Method Validated, Interconnected Transactions Recognized as Single Economic Unit

April 16, 2025

Case Laws Income Tax AT

You may also like:

The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for...

The High Court held that a change in the approach of assessing tax, without any statutory change, leads to uncertainty in cash flow and fund flow, which are crucial for...

ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely...

This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

Transfer Pricing Adjustments - downward adjustment made by the TPO and enhanced by the CIT(A) - adoption of the Transactional Net Margin Method (TNMM) over other methods...

The Appellate Tribunal (ITAT) considered Transfer Pricing (TP) adjustments related to foreign exchange gains and engineering services. The assessee used Transactional...

TP Adjustment - selection of most appropriate method (MAM) - Resale Price Method or Transactional Net Margin Method - Introduction of Fresh Comparables - Removal of 3%...

TP Adjustment - 'arranged' pricing' - TNMM method or CUP method - the superiority of any particular method to arrive at the ALP is ruled out.The TNMM (Transactional Net...

Transfer pricing adjustment - TNMM has almost become the ‘default’ method for taxpayers in recent years. - As such, the TNMM often proves easier to apply than, say, the...

ITAT adjudicated a transfer pricing dispute involving international transactions. The tribunal upheld the TPO's rejection of the assessee's transfer pricing study,...

With the passage of time where India is becoming a global commercial hub with the advent of Multinational Companies new transfer pricing issues are thrown up and keeping...

TP Adjustment - ALP is determined by TPO by not applying any method at all or by choosing a method which is not prescribed u/s.92C(1) of the Act, then such a...

The ITAT allowed the revenue's appeal for statistical purposes and remitted the matter back to the Assessing Officer to re-examine the issue and refer it to the Transfer...

Transfer Pricing Adjustment - arm's length price (ALP) of international transactions- MAM - “other method” - The Tribunal analyzed the transfer pricing methods applied...

Transfer pricing adjustment - most appropriate method - CUP method was not correct method - AO directed to apply TNMM method to benchmark the international transactions...

Quick Updates: