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“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
43
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
41
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
38
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
37
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
35
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
26
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
25
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

Assistant Commissioner of Income Tax, Kolhapur vs. Undercarriage and Tractor Parts Private Limited, Kolhapur

In the result, the appeal of the Revenue is dismissed

ITA 839/PUN/2024[2015-16]Status: DisposedITAT Pune07 Jan 2025AY 2015-16

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Tanzil TadvekarFor Respondent: Shri Pawan Bharati
Section 271GSection 92CSection 92DSection 92D(3)

pricing documentation as per rule 10D r.w.s. section 92D. Perusal of Transfer pricing study report shows that the appellant has adopted CUP as most appropriate method for all the transactions with the AEs. Following are the details given by the appellant in its TP study report on page

Shree Chandi Maa Mahakali Prachin Mandir Sidh Peeth Samiti, Sonipat vs. CPC, Banglore

ITA 4791/DEL/2024[2022-23]Status: DisposedITAT Delhi07 Jan 2025AY 2022-23

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

enterprise. In the Transfer Pricing Documentation, the international transactions were benchmarked using Transactional Net Margin Method (“TNMM”) method. By considering this method as Most appropriate method, the assessee has shown operating profit ratio of GGL at 27.26%, which as per assessee was higher than average of operating profit margin ... benchmarking the sale price to associated enterprise. 3.3 The TPO, for the purpose of computing the ALP, has applied CUP method as the most appropriate method, and has adopted following methodology for selection of the comparable uncontrolled transactions: (i) The sales made to associated enterprises and independent parties were segregated

Qubix Business Park Private Limited, Pune vs. Deputy Commissioner of Income Tax, Circle-8, Pune

In the result, Ground No.2 of the assessee is allowed for statistical purpose

ITA 1994/PUN/2024[2020-21]Status: DisposedITAT Pune06 Jan 2025AY 2020-21

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 115JSection 143(3)Section 144BSection 144C(13)Section 144C(5)Section 80

Learned Transfer Pricing Officer (‘Ld.TPO’) wherein the Ld.TPO has rejected the benchmarking conducted by the Assessee by adopting ‘CUP’ method as the most appropriate method for determining the Arm’s Length Price (‘ALP’) of the Assessee with respect to interest paid on loan taken from Embassy office Parks REIT ... Ld.TPO wherein the Ld.TPO has concluded that since an internal comparable is readily available in assessee’s case, CUP method is the most appropriate method to determine the arm’s length price of the subject transaction. 2.4 The Hon’ble. DRP and the Ld. TPO have erred in concluding that

Greenland Finance and Leasing P. Ltd., Delhi vs. ITO, New Delhi

In the result, the appeal of the Assesse in ITA No

ITA 1295/DEL/2019[2010-11]Status: DisposedITAT Delhi06 Jan 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 250(6)Section 92CSection 92C(3)Section 92D

Tube packaging; (d) Flavors. 11. As per TP Study Report (TPSR), the assessee company has choosen Transaction Net Margin Method (TNMM) as the Most Appropriate Method (MAM) and used operative profit/ total costs as the PLI. The TPO has modified certain quantitative/qualitative filters applied by the assessee and further ... taken in earlier years in terms of the loan agreement executed on different dates. The assessee selected the other method as most appropriate method to work out the Arms Length Price (‘ALP’) of such borrowings wherein the assessee has considered the market rate of interest on Indian Loans

Greenland Finance and Leasing P. Ltd., Delhi vs. ITO, New Delhi

In the result, the appeal of the Assesse in ITA No

ITA 1294/DEL/2019[2009-10]Status: DisposedITAT Delhi06 Jan 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 250(6)Section 92CSection 92C(3)Section 92D

Tube packaging; (d) Flavors. 11. As per TP Study Report (TPSR), the assessee company has choosen Transaction Net Margin Method (TNMM) as the Most Appropriate Method (MAM) and used operative profit/ total costs as the PLI. The TPO has modified certain quantitative/qualitative filters applied by the assessee and further ... taken in earlier years in terms of the loan agreement executed on different dates. The assessee selected the other method as most appropriate method to work out the Arms Length Price (‘ALP’) of such borrowings wherein the assessee has considered the market rate of interest on Indian Loans

ACIT 6(1)(1), Mumbai, Aayakar Bhavan vs. Clear Secured Services Private Limited, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 3758/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Dec 2024AY 2015-16

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI. PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri. Shashank MehtaFor Respondent: Shri. Kiran Unavekar Sr. DR
Section 115JSection 143(1)Section 143(3)Section 250

appeal of the assessee by upholding the benchmarking done by 2 M/s. Clear Secured Services Pvt. Ltd. assessee under Cost Plus Method as Most Appropriate Method (MA) and rejecting the method adopted by TPO i.e. Transactional Net Margin Method (TNMM) as most Appropriate Method (MA) for benchmarking? 3. The Appellant

Zuari Cement Limited, Kadapa vs. DCIT Circle -1, Nellore

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 502/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Deepak Chopra, Advocate and Shri Nitin Narang,C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 144C(5)Section 92D

length price ("ALP") of the international transactions. Grounds on Rejection of combined Transactional Net Margin Method ("TNMM") selected as Most Appropriate Method ("MAM") by the Appellant and adopting Comparable Uncontrolled Price ("CUP") Method/ Other Method without any comparable transaction or any basis for applying such method. 5. That

Decathlon Sports India Private Limited, Bangalore, Karnataka vs. Deputy Commissioner of Income-Tax Circle 2(2)(1), Bengaluru, Karnataka

In the result appeal of the assessee is partly allowed as indicated

ITA 1874/BANG/2024[2020-2021]Status: DisposedITAT Bangalore26 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi

For Appellant: Shri Chavali Narayan, CA
Section 143(3)Section 92C

transaction approach adopted by the Appellant to benchmark the receipt of intra-group services transaction considering transactional net margin method (“TNMM7”) as the most appropriate method (“MAM”) The Ld. AO /TPO /DRP, erred by determining the arm’s length price (“ALP”) of the impugned transaction without reasonably applying any prescribed ... Decathlon Italy [Purchase of Rs 3752255/-] and Decathlon Portugal [Purchase of Rs 2118788/-]. Assessee selected the Transactional Net Margin Method [TNMM] as the Most Appropriate Method selecting Desipro (foreign entity) as a tested party, from whom 99 % of Purchases are made, stating that operations performed by it are less complex

Ims Health Analytics Services Private Limited, Bangalore vs. Income Tax Officer, Ward-3(1)(1), Bangalore

ITA 300/BANG/2022[2017-18]Status: DisposedITAT Bangalore18 Dec 2024AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyit(Tp)A No.300/Bang/2022

For Appellant: Shri Ajit Tolani & Sri Darpan Kriplani, CAFor Respondent: Shri A Sreenivasa Rao, CIT (DR)

including the provision of IteS Services. The assessee to benchmark such international transaction (provision of ITES services) has adopted the TNMM method as most appropriate method to compute the ALP. The assessee by applying the TNMM method computed its PLI as OP/OC which comes 14.79% and based on TP study ... assessee), is nowhere supported by the TNMM under Rule 10B(1)(e) of the Rules. Having determined that (TNMM) to be the most appropriate method, the only rules and norms prescribed in that regard could have been applied to determine whether the exercise indicated by the assessee yielded

Nefab India Private Limited, Pune vs. DCIT, Circle-3(1), Gurgaon

ITA 509/DEL/2022[2017-18]Status: DisposedITAT Delhi18 Dec 2024AY 2017-18

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2017-18 Nefab India Pvt. Ltd., Vs Dcit, Gate No.519 1/4/8, Circle 3(1), 30 Km. Milestone, Gurgaon. Near Kalubai Mandir, Golden Quadrilateral Nh-4, Pune, Maharashtra – 412213. Pan : Aaccn1599G

For Appellant: Shri Ajit Kumar Jain, CAFor Respondent: Shri Zafarul Haque Tanveer, CIT-DR
Section 143(3)

comes up that primarily the assessee has challenged the finding of the ld. tax authorities below rejecting the economic analysis including selection of Most Appropriate Method as undertaken by the assessee in its transfer pricing documentation. The case of the assessee is that the ld. tax authorities below have failed

DCIT, Circle- 8(1), New Delhi vs. E.I. Dupont India P. Ltd., Gurgaon

In the result, the appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 7454/DEL/2017[2008-09]Status: DisposedITAT Delhi18 Dec 2024AY 2008-09

Bench: Shri M. Balaganesh & Shri Sudhir Kumarcorteva Agriscience India Pvt Ltd Vs. Dcit, (Earlier Known As E.I. Dupont P. Circle-11(1), Ltd), 17Th Floor, Tower-C, Dlf New Delhi Cyber Greens, Sector-25A, Phase-3, Gurgaon (Appellant) (Respondent) Pan: Aaace2462M Dcit, Vs. Corteva Agriscience India Circle-11(1), Pvt Ltd (Earlier Known As E.I. Dupont P. Ltd), 17Th New Delhi Floor, Tower-C, Dlf Cyber Greens, Sector-25A, Phase-3, Gurgaon (Appellant) (Respondent) Pan: Aaace2462M Assessee By : Shri Deepak Chopra, Adv Shri Harpreet Singh Ajmani, Adv Shri Pulkit Pandey, Adv Revenue By: Shri Chetan Rao, Cit Dr Date Of Hearing 25/09/2024 Date Of Pronouncement 19/12/2024

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Chetan Rao, CIT DR
Section 144C

erred in law and on facts in accepting the CUP method as used by the Ld. TPO as the Most Appropriate Method instead of the TNMM method adopted by the Appellant. The Ld. CIT(A) has also erred in not accepting the alternate CUP analysis provided by the Appellant ... availing support services from AEs by using Transactional Net Margin ITA No. 7454/Del/2017 Corteva Agriscience India Pvt Ltd Method (TNMM) as the Most Appropriate Method (MAM). The Profit Level Indicator adopted by the assessee was Operating Profit divided by Operating cost (OP / OC). The assessee had incurred administrative support services

E.I. Dupont India P. Ltd., Gurgaon vs. DCIT, Circle- 11(1), New Delhi

In the result, the appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 6879/DEL/2017[2008-09]Status: DisposedITAT Delhi18 Dec 2024AY 2008-09

Bench: Shri M. Balaganesh & Shri Sudhir Kumarcorteva Agriscience India Pvt Ltd Vs. Dcit, (Earlier Known As E.I. Dupont P. Circle-11(1), Ltd), 17Th Floor, Tower-C, Dlf New Delhi Cyber Greens, Sector-25A, Phase-3, Gurgaon (Appellant) (Respondent) Pan: Aaace2462M Dcit, Vs. Corteva Agriscience India Circle-11(1), Pvt Ltd (Earlier Known As E.I. Dupont P. Ltd), 17Th New Delhi Floor, Tower-C, Dlf Cyber Greens, Sector-25A, Phase-3, Gurgaon (Appellant) (Respondent) Pan: Aaace2462M Assessee By : Shri Deepak Chopra, Adv Shri Harpreet Singh Ajmani, Adv Shri Pulkit Pandey, Adv Revenue By: Shri Chetan Rao, Cit Dr Date Of Hearing 25/09/2024 Date Of Pronouncement 19/12/2024

For Appellant: Shri Deepak Chopra, AdvFor Respondent: Shri Chetan Rao, CIT DR
Section 144C

erred in law and on facts in accepting the CUP method as used by the Ld. TPO as the Most Appropriate Method instead of the TNMM method adopted by the Appellant. The Ld. CIT(A) has also erred in not accepting the alternate CUP analysis provided by the Appellant ... availing support services from AEs by using Transactional Net Margin ITA No. 7454/Del/2017 Corteva Agriscience India Pvt Ltd Method (TNMM) as the Most Appropriate Method (MAM). The Profit Level Indicator adopted by the assessee was Operating Profit divided by Operating cost (OP / OC). The assessee had incurred administrative support services

L'Oreal India Private Limited, Mumbai vs. Income Tax Department, Mumbai

ITA 4577/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 Dec 2024AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarl'Oreal India Private V/S. Assistant Commissioner Of Limited, A-Wing, 8Th Floor, Marathon Futurex, N.M. Joshi Marg, Lower Parel, Mumbai Maharashtra 400 013, बनाम Income Tax- 7(1)(1), Aayakar Bhavan, M.K. Road, Mumbai 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaacl0738K Appellant/अपीलार्थी .. Respondent/प्रतिवादी Appellant By : Shri Niraj Sheth Respondent By : Ms. Neena Jeph (Cit Dr) Date Of Hearing 19.11.2024 Date Of Pronouncement 16.12.2024 आदेश / Order Per Prabhash Shankar [Α.Μ.] This Is An Appeal Filed By The Assessee, Challenging The Assessment Order Passed By The Assessing Officer/Transfer Pricing Officer (‘Tpo' For Short) Pursuant To The Direction Of The Hon'Ble Dispute Resolution Panel ('Drp' For Short), Passed U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Relevant To The Assessment Year (A.Y. For Short) 2020-21.The Assessee Has Challenged The Grounds Of Transfer Pricing Adjustment On Account Of Advertisement, Marketing & Promotion (Amp) Expenses. Following Are The Grounds Raised By The Assessee: Page 2

For Appellant: Shri Niraj ShethFor Respondent: Ms. Neena Jeph (CIT DR)
Section 143(3)Section 4Section 92Section 92BSection 92C

Page 1 ITA No. 4577/MUM/2024 (A.Y. 2020-21) IN THE INCOME-TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI SANDEEP

International Packaging Products Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 4225/MUM/2024[2020-21]Status: HeardITAT Mumbai16 Dec 2024AY 2020-21

Bench: Us, Following Grounds Of Appeal Have Been Pressed: -

Section 234CSection 92C

semi-finished goods from the AE of Rs.69,38,36389/- and old balances written back of Rs.14,13,028/- and applied TNMM as Most Appropriate Method. Assessee had shortlisted 23 comparables and held that the range of weighted average of OP/OC of the comparable companies is 1.34% to 3.95% with

Robert Bosch Engineering and Business Solutions Private Limited, Bengaluru vs. The Joint Commissioner of Income Tax, Large Tax Payers Unit, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

OP/OC ratio of 12.94% only. 38.3 In the Transfer Pricing (TP) study, the assessee adopted the Transactional Net Margin Method (TNMM) as the most appropriate method and used the Operating Profit to Operating Cost (OP/OC) ratio as the Profit Level Indicator (PLI). The assessee selected a different set of comparables

Deputy Commissioner of Income Tax, Circle- 2, Ltu, Bengaluru vs. M/S. Robert Bosch Engineering and Business Solutions Private Limited, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

OP/OC ratio of 12.94% only. 38.3 In the Transfer Pricing (TP) study, the assessee adopted the Transactional Net Margin Method (TNMM) as the most appropriate method and used the Operating Profit to Operating Cost (OP/OC) ratio as the Profit Level Indicator (PLI). The assessee selected a different set of comparables

Concur Technologies (India) Private Limited, Bengaluru vs. Assistant Commissioner F Income Tax Circle 2(2)(1), Bengaluru

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1925/BANG/2024[2020-2021]Status: DisposedITAT Bangalore05 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(5)Section 92B

subsumed within the arm's length price determination of the principal transactions itself using the transactional net margin method ("TNMM") es the most appropriate method in the 1'P study report. The learned AO/ TPO has also erred in law and facts by treating outstanding IT(TP)A No.1925/Bang/2024 Page

Otis Elevator Company (India) Limited, Mumbai vs. DCIT, 13(1)(2), Mumbai

ITA 3337/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 Nov 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Bleι.Τ.Α. No. 3337/Mum/2024

For Appellant: Shri Rajan Vora & Nikhil Tiwari, A/RsFor Respondent: Shri Asif Karmali, Sr. D/R
Section 143(3)Section 144C(13)Section 234ASection 234CSection 234FSection 270A(1)Section 37(1)Section 92CSection 92C(3)

erred in not accepting Transactional Net Margin Method ('TNMM') adopted by the Appellant with its AE as the tested party as the most appropriate method for the purpose of benchmarking the international transaction of payment of management fee; Disregarding the commercial nature of transaction: 9. erred in making an alternate

ACIT-5(1)(1), Mumbai vs. Ankit Gems Pvt.Ltd., Mumbai

In the result, Revenue’s appeal is dismissed

ITA 2579/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Nov 2024AY 2013-14

Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri Sanjay ChokshiFor Respondent: Ms. Neena Jeph
Section 250Section 271GSection 92CSection 92DSection 92D(3)

AO/TPO has considered the methods adopted by the assessee for determining the arms length price, were TNNM was held to be a most appropriate method. The ld. AR also stated that on identical facts the Tribunal has held this issue in favour of the assessee ... purchase and sale of rough diamond and polish diamond. The assessee has benchmarked the said transactions by taking TNNM method as most appropriate method using operating profit/sales as Profit Level Indicator (PLI). The assessee had taken the margin at entity level and had compared the transactions with the comparable companies

Benu Networks Packet Switch Private Limited, Hyderabad vs. DCIT, Circle -1 (2), Hyderabad

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

ITA 86/HYD/2022[2017-18]Status: DisposedITAT Hyderabad25 Nov 2024AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita No.86/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) Benu Networks Packet Switch Vs. Dy. Commissioner Of Income Tax, Circle 1(1) Private Ltd, Hyderabad Hydrabad Pan:Aaecb4902B (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ashish Jain, Ca राज" व "ारा/Revenue By:: Shri B Balakrishna, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 25/11/2024 आदेश/Order

For Appellant: Shri Ashish Jain, CAFor Respondent: : Shri B Balakrishna, DR
Section 143(3)Section 144C(5)Section 92B

Benu Networks Packet Switch P Ltd assessee has benchmarked its international transactions by applying TNMM as most appropriate method and selecting 16 comparable companies having 36 percentile at 5.6% and 66 percentile 10.4% and claimed that the profit margin of the assessee at 15% is at Arms’ Length