“most appropriate method”

Transfer PricingSection 92CSection 92C1,345 judgments

The decision most relied on for most appropriate method is CIT v. Cushman & Wakefield (India) (P.) Ltd. (367 ITR 730), cited in 120 judgments on BharatTax.

Leading authorities on most appropriate method

CIT v. Cushman & Wakefield (India) (P.) Ltd.

367 ITR 730 · 2014 · High Court

120

citing judgments

This case determines the Arm's Length Price (ALP) for intra-group services and reimbursements, clarifying when charges constitute services warranting a mark-up versus mere pass-through costs. It provides guidance on the circumstances under which an ALP adjustment, including an ALP of 'nil', is appropriate for such transactions.

Dresser-Rand India (P.) Ltd. v. Addl. CIT

13 Taxmann.com 82 · 2011 · High Court

citing judgments

An Assessing Officer cannot disregard an assessee's decision to avail services from associated enterprises, even if the assessee has internal expertise, as the determination of necessity is the assessee's prerogative. The Transfer Pricing Officer's role is to determine the arm's length price, not the need for the service itself.

CIT v. EHPT India P Ltd.

350 ITR 41 · 2013 · High Court

citing judgments

The headcount method is an appropriate allocation key for indirect expenses between eligible and non-eligible units when it has been consistently accepted by revenue authorities and there is no just cause for abandoning it. Deviation from a consistently followed and accepted method can disturb or distort profits.

Mobis India Ltd. v. Dy. CIT

38 Taxmann.com 231 · 2013 · ITAT

citing judgments

A working capital adjustment is unreliable if it is based on broad approximations, estimations, and assumptions, and the assessee fails to demonstrate how the adjustment was arrived at.

LG Electronics India Pvt. Ltd. v. ACIT

29 Taxmann.com 300 · 2013 · High Court

citing judgments

The 'bright line test' is not an appropriate method for determining the existence of an international transaction for calculating arm's length price. This ruling overrules prior special bench decisions on AMP expenses.

Magneti Marelli Powertrain India Pvt. Ltd. v. DCIT

389 ITR 469 · 2016 · High Court

citing judgments

The Assessing Officer (AO) or Transfer Pricing Officer (TPO) cannot dispute the application of the TNMM method if they have already accepted it as the most appropriate method for certain international transactions, especially when other transactions are intrinsically linked.

Skoda Auto India (P) Ltd. v. ACIT, Aurangabad

30 SOT 319 · 2009 · ITAT

citing judgments

The Tribunal may allow adjustments for differences between the tested party and comparable companies to eliminate material differences, provided accurate and credible evidence is furnished.

Principal Commissioner of Income-tax-6 v. Matrix Cellular International Services (P.) Ltd.

90 Taxmann.com 54 · 2018 · High Court

citing judgments

The Resale Price Method (RPM) is the most appropriate method for determining the arm's length price of a distributor who does not add significant value to the goods purchased.

Judgments citing most appropriate method

DCIT, New Delhi vs. M/S. Fis Global Business Solutions India Pvt. Ltd., New Delhi

In the result, both appeals of the revenue stand dismissed and both Cos are allowed as above

ITA 2387/DEL/2014[2008-09]Status: DisposedITAT Delhi09 May 2025AY 2008-09

Bench: SHRI AVDHESH KUMAR MISHRA (Accountant Member)

networks and gateways remarketers and e-commerce providers. 4.1 The assessee adopted the Transactional Net Margin Method (TNMM) on segmental basis as the most appropriate method for both segments i.e. SDS and ITeS and Operating Profit by Operating Cost as the profit level indicator ("PLI"), which, in principle, has been ... comparables in this segment also. FOR AY 2008-09 51. The assessee has chosen TNMM on a segmental basis as the most appropriate method for both segments i.e. SDS and ITeS Segment and Operating Profit by Operating Cost as the profit level indicator ("PLI"), which, in principle, has been accepted

DCIT, New Delhi vs. Fis Global Business Solution India (P) Ltd., New Delhi

In the result, both appeals of the revenue stand dismissed and both Cos are allowed as above

ITA 5939/DEL/2012[2007-08]Status: DisposedITAT Delhi09 May 2025AY 2007-08

Bench: SHRISUDHIR KUMAR (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Biogenex Life Sciences Private Limited, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 68/HYD/2022[2017-18]Status: DisposedITAT Hyderabad07 May 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: : Smt. M. Narmada, CIT-DR

Section 143(3)Section 92C

Study and Documentation submitted by the assessee company. 4.3. ought to have considered the revised TP study report by taking TNMM as most appropriate method for benchmarking the transaction by aggregating the transactions under taken during the year as all the transactions are closed linked to each other. 4.4. ought

Mane India Private Limited, Hyderabad vs. ACIT., Circle-5(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 686/HYD/2024[AY 2020-21]Status: DisposedITAT Hyderabad06 May 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.686/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) M/S Mane India (P) Ltd Vs. Acit Hyderabad Circle 5(1) Pan:Aaccm1243J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Mahima Goud राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 11/02/2025 घोषणा की तारीख/Pronouncement: 06/05/2025 आदेश/Order

For Appellant: Advocate Mahima GoudFor Respondent: : Smt. M. Narmada, CIT(DR)

Section 143(3)Section 144C(5)

transactions by aggregating the above international transactions including the payment towards management and technical assistance services to the AE under TNNM as the most appropriate method. The TPO has held that the assessee has not furnished any details of formula that were transferred by the AE Page ... relevant material available on record. The assessee has benchmarked all these transactions by aggregating the international transactions and applying TNNM as the most appropriate method. It is pertinent to note that the aggregation of the international transactions are permitted only when the transactions are closely linked and dependent upon each

International Seaport Dredging Limited, Chennai vs. DCIT, Chennai

The appeal stand allowed

ITA 72/CHNY/2018[2013-14]Status: DisposedITAT Chennai02 May 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

For Appellant: Shri Ashik Shah (C.A) – Ld.ARFor Respondent: Shri A.Sasi Kumar (CIT) -Ld. DR

Section 143(3)

respect of uncontrolled transactions which were similar to transactions of assessee with its foreign associated enterprise, CUP method could not be considered as most appropriate method to determine arm's length price (ALP) of royalty paid by assesse to its AE for technology collaboration" (b) The Hon'ble Chennai Bench ... respect of uncontrolled transactions which were similar to transactions of assessee with its foreign associated enterprise, CUP method could not be considered as most appropriate method to determine arm's length price (ALP) of royalty paid by assesse to its AE for technology collaboration". Similarly, the Chennai Bench

Icici Bank Ltd, Mumbai vs. Addl CIT RG 3 (1), Mumbai

ITA 4249/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR

Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

Britain UK & Canada. The assessee bench marked the transaction by treating it as ITES service provider. The assessee had selected TNMM as most appropriate method and PLI to OP/TC to computed its merger at 10%. 2. 4. The assessee selected following 8 comparables with an average margin of 9.53%. Comparable ... ordinate bench of this Tribunal for AY.2007-08 (supra). 7. 2. On the contrary, the Ld.DR submitted that assessee adopted TNMM as the most appropriate method and there cannot be directed co-relation between the revenue earned and the employee cost under such circumstances. It is submitted that assessee is rendering

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

ITA 4159/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR

Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

Britain UK & Canada. The assessee bench marked the transaction by treating it as ITES service provider. The assessee had selected TNMM as most appropriate method and PLI to OP/TC to computed its merger at 10%. 2. 4. The assessee selected following 8 comparables with an average margin ... ordinate bench of this Tribunal for AY.2007-08 (supra). 7. 2. On the contrary, the Ld.DR submitted that assessee adopted TNMM as the most appropriate method and there cannot be directed co-relation between the revenue earned and the employee cost under such circumstances. It is submitted that assessee is rendering

Deputy Commissioner of Income Tax, Circle 8 Pune, Pune vs. Alfa Laval India Pvt Ltd, Pune

In the result, the appeal of the Revenue is partly allowed

ITA 1723/PUN/2024[2017-18]Status: DisposedITAT Pune29 Apr 2025AY 2017-18

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1723/Pun/2024 Assessment Year : 2017-18

For Appellant: Shri H. AnandaFor Respondent: Shri Nikhil Pathak

Section 143Section 143(2)Section 143(3)Section 92C

incorrect. 1(b). On the facts and circumstances of the case, the Ld. CIT(A) erred in rejecting CPM as most appropriate method for benchmarking the transaction of 'export of traded spares', without taking cognizance of the categorical finding given by TPO in Para 41 of his order that ... based on gross profits. 1(c) On the facts and circumstances of the case, the l.d. CIT(A) erred in rejecting CPM as most appropriate method for benchmarking the transaction of 'export of traded spares, without taking cognizance of the categorical finding given by TPO in Para

The Dcitbharuch Range, Bharuch vs. Heubach Colour Pvt.Ltd., Ankleshwar

In the result, Ground Number 3 of the Department’s appeal is dismissed

ITA 547/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad21 Apr 2025AY 2007-08

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Amrin Pathan, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT-DR

Asst.Year –2007-08 - 6– obligations further complicated the CUP application, and it was deemed improper to rely on CUP as the most appropriate method for determining the ALP of intangibles. Moreover, the assessee's use of hindsight in justifying the ALP based on later developments was also rejected. Considering ... procurement, and other business functions, which justified its classification as the full-fledged manufacturing entrepreneur. Accordingly, the TPO rejected TNMM as the most appropriate method, suggesting that the Profit Split Method (PSM) would have been a more correct approach due to the shared intangibles between the assessee and Colour

Assistant Commissioner of Income Tax Ltu Circle 1 Chennai, Chennai vs. E I D Parry India Limited, Chennai

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3251/CHNY/2024[2012-13]Status: DisposedITAT Chennai21 Apr 2025AY 2012-13

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT

Section 143(1)Section 143(2)Section 250Section 92BSection 92C

assessee for issue of LOC. The same along with 0.5% of Risk may be considered as ALP and CUP is considered as Most Appropriate Method. 7. Based on the above facts and the rates levied by the bank, the TPO considered the same as ALP which ... India, Chennai charges 1% along with Service Tax for issue of LOC. Therefore, the TPO applied the comparable uncontrolled price method as the most appropriate method and applied the same along with 0.5% of risk to determine the Arm's Length Price of this transaction, which

M/S. Eid Parry India Ltd., Chennai vs. DCIT, Ltu-1, Chennai

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

ITA 3113/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Apr 2025AY 2014-15

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri A. Sasikumar, CIT

Section 143(1)Section 143(2)Section 250Section 92BSection 92C

M/S Lubrizol India Private Limited, Mumbai vs. The Office of the Deputy Commissioner of Income Tax, DCIT/ACIT, Circle-3(4), Mumbai

In the result, the appeals of assessee for both AYs are allowed

ITA 6099/MUM/2024[2021-22]Status: DisposedITAT Mumbai21 Apr 2025AY 2021-22

Bench: Shri Pawan Singh & Shri Girish Agrawal & (Physical Hearing) M/S. Lubrizol India Private Limited Deputy Commissioner Of Plant 9/3, Thane-Belapur Road, Turbhe, Vs Income Tax, Dcit/Acit, Navi Mumbai – 400705. Circle – 3(4), Mumbai. [Pan No. Aaacl 0126 H] Appellant / Assessee Respondent / Revenue Assessee By Shri Paras Savla Advocate A/W Ms. Rajnandini Shukla, Ca/ Ar Revenue By Ms. Neena Jeph, (Cit Dr) / Shri Kiran Unavekar, Sr. Dr Date Of Hearing 27.03.2025 Date Of Pronouncement 21.04.2025 Order Under Section 254(1) Of Income Tax Act

Section 254(1)

Rule 100 of the Income-tax Rules, 1962 ("Rules"). 3. Erred in rejecting the application of Transactional Net Margin Method ("TNMM") as the Most Appropriate Method ("MAM") used by the Appellant for benchmarking the international transaction in respect of its exports of chemical additives to its associated enterprise ... international transaction with regard to export of chemical additives to its foreign AEs. The assessee adopted Transaction Net Margin Method (TNMM) as the most appropriate method. The TPO entered into reference and rejected the most appropriate method adopted by assessee. The TPO applied Comparable Uncontrolled Price (CUP) method

Lubrizol India Private Limited, Mumbai vs. DCIT, Circle-3(4), Mumbai

In the result, the appeals of assessee for both AYs are allowed

ITA 4630/MUM/2024[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Section 254(1)

Tupperware India Private Limited, New Delhi vs. DCIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 462/DEL/2022[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR

Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

giving workings thereon. It was also submitted that the assessee had applied Transactional Net Margin Method (TNMM) as the most appropriate method (MAM) for benchmarking the international transaction qua the export of finished goods to its AEs which has been accepted by the ld TPO. The ld AR placed reliance ... parties and perused the material available on records The Ld. TPO as well as the Hon'ble DRP has upheld CUP as the most appropriate method for benchmarking transactions with respect to payment of royalty Since the application of CUP is not disputed either

Tupperware India Private Limited, New Delhi vs. ACIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 2409/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Apr 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR

Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

Ariston Group India Private Limited, Pune vs. The Assessement Unit, Income Tax Department, NFAC and the DCIT, Circle 1(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 1680/PUN/2024[2020-21]Status: DisposedITAT Pune09 Apr 2025AY 2020-21

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

Section 143(3)Section 144Section 144BSection 144C(13)Section 37(1)Section 92C

availed and used these services for the purpose of its business activities and has derived benefit from such services. 2 Erroneous rejection of most appropriate method and benchmarking analysis: 2.1 The Ld. AO/TPO pursuant to the directions of the Hon'ble DRP erred in law and on the facts ... circumstances of the case in rejecting Transactional Net Margin Method (TNMM') as most appropriate method and transfer pricing documentation maintained by the Appellant. 2.2 The Ld. AO/TPO pursuant to the directions of the Hon'ble DRP erred in law and on the facts and in circumstances of the case

Hammond Power Solutions Private Limited, Hyderabad vs. DCIT, Circle 2(1), Hyderabad

In the result, the appeal of the assessee is dismissed

ITA 76/HYD/2022[2017-18]Status: DisposedITAT Hyderabad09 Apr 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon’Ble

For Appellant: Shri P.V.S.S. Prasad, C.AFor Respondent: Ms. M. Narmada, CIT-DR

Section 143(3)Section 92C

Stewardship services Rs. 1,07,77,840 4. The Approach adopted by the Ld. DRP/AO of using other method as Most Appropriate method is not justified, since reimbursement of legitimately incurred cost by AE in rendering services had been disallowed treating it as Nil. 5. The Ld. DRP/AO erred

Aon Consulting Private Limited, New Delhi vs. DCIT, Circle-1(1), Delhi

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 739/DEL/2022[2017-18]Status: DisposedITAT Delhi09 Apr 2025AY 2017-18

Bench: Shri Vikas Awasthy & Shri Pradip Kumar Kediaआअसं.739/िद"ी/2022(िन.व. 2017-18) M/S Aon Consulting P. Ltd., Aon Centre, 9Th To 11Th, Building No.2, Unitech Realty Projects Ltd., (Sez), Village Tikri, Sector 48, Gurgaon, Haryana 122001 ...... अपीलाथ"/Appellant Pan: Aahca-0739-J बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 1(1), Delhi Assessee By : Shri Darpan Kirpalani, Advocate Department By : S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 17/01/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 09/04/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed The Assessment Order Dated 22.02.2022 Passed U/S. 143 R.W.S. 144C(13) R.W.S 144B Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’). 2. The Assessee In Appeal Has Assailed Transfer Pricing Adjustment Made In Respect Of Software Development Services Segment. The Assessee Has Also Assailed Some Additions On Corporate Issue, Viz. Disallowance Made U/S. 14A R.W.S. 8D & Additions Based On Intimation U/S. 143(1) Of The Act.

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: S/Shri Rajesh Kumar & Rajesh Kumar Dhanesta, Sr. DR

Section 143Section 143(1)Section 14A

profit/total cost (OP/TC) is 15.38%. The assessee selected ten companies as comparables having average margin of 10.43%. The TPO accepted TNMM as the most appropriate method to bench mark international transaction, however, the TPO rejected six companies from list of comparables selected by the assessee and introduced nine fresh companies ... reliance to buttress his arguments for exclusion of companies from the list of comparables. In so far as selection of TNMM as the most appropriate method, there is no dispute. The TPO has accepted the same. The bone of contention between the rival sides is only the companies selected

Dr. Bhim Rao Ambedkar Mahasang Haryana, Faridabad vs. CIT (Exemptions), Chandigarh/Faridabad

In the result, both the appeals are partly allowed for statistical purposes

ITA 3196/DEL/2023[NA]Status: DisposedITAT Delhi08 Apr 2025

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarita No. 3195/Del/2017 Assessment Year: 2003-04 Ita No. 3196/Del/2017 Assessment Year: 2004-05 Geodis Overseas Pvt.Ltd., Vs. Asstt. Commissioner Of Building No.5,Tower B, Income Tax, 10Th Floor, Dlf Cyber City, Company Circle- Ii(1), Phase Iii, Gurgaon Chennai-34 Pin: 122 002 Pan No. Aaacc6168L (Appellant) (Respondent)

For Appellant: Shri Vishal Kalra, Adv. & ShriFor Respondent: Ms. Neeju Gupta, Sr. DR

Section 250Section 92C

provisions of the Act. The Appellant has benchmarked the international transactions pertaining to freight forwarding using. Transactional Net Margin Method ("TNMM") as the most appropriate method with net profit margin ("NPM") on sales (refer pages 461 to 469 of the paper book). 12.2 The TPO vide order dated February ... import transactions related to controlled and uncontrolled transactions”. It was also noted that while the transfer pricing study report mentions CUP as most appropriate method, the related column in the Form 3CEB states that TNMM (Transaction Net Margin Method) is most appropriate method, even as the assessee subsequently clarifies that

Capita India Private Limited, Mumbai vs. Assessment Unit, National Faceless Assessment Centre (NFAC), Mumbai

ITA 4954/MUM/2024[AY 2020-21]Status: DisposedITAT Mumbai07 Apr 2025

For Respondent: Shri Kiran Unavekar

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER