“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, Circle-1(1)(1), Ahmedabad vs. Atul Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1774/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 271GSection 92CSection 92DSection 92D(3)

goods from Amal Ltd. In this case, the Ld. TPO rejected the CUP method applied by the appellant and adopted TNMM method as most appropriate method (MAM). The appellant filed objection before Hon'ble DRP and Hon'ble DRP accepted the CUP as MAM. The only modification made ... length price in relation to each international transaction or specified domestic transaction or class of transaction, the method selected as the most appropriate method along with explanations as to why such method was so selected, and how such method was applied in each case; (j) a record of the actual

Lear Automotive India P. Ltd., Pune vs. Assistant Commissioner of Income Tax, Circle-8, Pune

ITA 554/PUN/2024[2016-17]Status: DisposedITAT Pune10 Oct 2025AY 2016-17

For Appellant: Shri Dhanesh Bafna &For Respondent: Shri Prakash L. Pathade

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

आयकर अपीलीय अधिकरण “सी” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, PUNE BEFORE SHRI R.K. PANDA

DCIT, Circle 8 Pune, Pune vs. Alfa Laval India Pvt Ltd, Pune

ITA 2270/PUN/2024[2018-19]Status: DisposedITAT Pune10 Oct 2025AY 2018-19

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

Section 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(va)Section 40Section 92C

incorrect. 1.2. On the facts and circumstances of the case and in law, 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 ... gross profits. 1.3. On the facts and circumstances of the case and in law, 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

Te Connectivity India Private Limited, Bangalore vs. The Office of the Deputy Commissioner of Income-Tax, Circle 7(1)(1), Bangalore

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

ITA 2346/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Oct 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Dr. KJ Dhivya, CIT (DR)

goods - Sale return of raw materials - Payment of Royalty. 6. The assessee to determine the ALP of the manufacturing segment adopted TNMM as most appropriated method and taken OP/OR as PLI. Further, the assessee after study of public database and FAR analysis selected 6 comparable companies, the margin of which ... also contended that the approach of the TPO in determining the ALP at NIL without selecting the most appropriate method under Rule 10B is contrary to the mandate of section 92C of the Act. The law requires the adoption of one of the prescribed methods – CUP, RPM, CPM, PSM, TNMM

DCIT, Circle - 3(1), Visakhapatnam vs. Snf India Private Limited, Visakhapatnam

ITA 210/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2014-15

Bench: Shri Ravish Sood, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.T.A.No.204/Viz/2025 (निर्धारणवर्ष/ Assessment Year:2016-17) M/S. Snf (India) Private Limited 19 Jnpc, Ramky Pharmacity Paravada, Visakhapatnam – 531021 Andhra Pradesh [Pan:Aaacp4070A] Vs. Dcit - Circle – 3(1) Income Tax Office Infinity Towers, Sankarmat Road Visakhapatnam – 530016 Andhra Pradesh आयकर अपीलसं./I.T.A.Nos.209 & 210/Viz/2025 (निर्धारणवर्ष/ Assessment Years:2016-17 & 2014-15) Dcit - Circle – 3(1) 35,50-92-35, Sankaramatam Road Opposite Reliance Fresh, Beside Reliance Fresh, Nearby Main Road Madhuranagar, Dwarakanagar Visakhapatnam – 530016 Vs. M/S. Snf (India) Private Limited Plot No. 19 Ponnuru Village, Parawada Mandal Visakhapatnam – 531021 Andhra Pradesh [Pan:Aaacp4070A] करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement Shri Kanchan Kaushal, Ca Shri Badicala Yadagiri, Cit(Dr) 01.09.2025 08.10.2025

Section 142(1)Section 143(2)Section 92C

short listed nine comparables for bench-marking the international transactions. Assessee has adopted Transactional Net Margin Method (in short “TNMM”) as the most appropriate method (MAM). Accordingly, the margin (OP/OR) of the comparable was arrived in the range from 3.57% to 6.85%, whereas the PLI of the assessee stood ... relying on the jurisdictional bench decision in assessee's own case for the A.Ys.2007-08 & 2008-09 held that TNMM is the most appropriate method for determining the royalty payment and directed the Ld. AO to delete the adjustment of Rs.6,10,99,987/-. Similarly, on the issue

DCIT, Circle - 3(1), Visakhapatnam vs. Snf India Private Limited, Visakhapatnam

ITA 209/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2016-17

Section 142(1)Section 143(2)Section 92C

Honda R&D (India) Private Limited, Gurgaon vs. DCIT, Circle-10(1), Delhi

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

ITA 4930/DEL/2024[2021-22]Status: DisposedITAT Delhi08 Oct 2025AY 2021-22

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekhonda R&D (India) Private Limited, Vs. Dcit, Circle 10(1), Technical Centre Plot No.2, Delhi. Sector 3, Imt Manesar, Gurugram – 122 052 (Haryana). (Pan : Aabch3071N) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Revenue By : Shri Dharm Veer Singh, Cit Dr Date Of Hearing : 01.10.2025 Date Of Order : 08.10.2025 O R D E R Per S. Rifaur Rahman:

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR

Section 143(3)Section 144C(5)Section 92C

efficient functioning of its operations and are not duplicative. 3 5.3 Impugned Order erred in arbitrary selection of Other method as a Most appropriate method in the present case. NIL as ALP was mere Ipse dixit of TPO. 5.4 Impugned Order erred in assuming the ALP for the impugned transactions ... profit margin, not the full reimbursed amount. 6.3 The Impugned Order erred in arbitrary selection of Other method as a Most appropriate method in the present case. NIL as ALP was mere Ipse dixit of TPO. 6.4 The Impugned Order erred in making the impugned adjustment without presenting any analysis

Jogpl Pvt Ltd, Uttar Pradesh vs. DCIT Circle-13(1) Delhi, Delhi

In the result, the appeal of the assessee is partly allowed for 14

ITA 1718/DEL/2022[2017-18]Status: DisposedITAT Delhi08 Oct 2025AY 2017-18

Bench: Shri C. N. Prasad & Shri M. Balaganeshjogpl Pvt. Ltd, Vs. Dcit, Plot No. 15, Knowledge Circle-13(1), Park-2, Greater Noida, Delhi Up 2011306 (Appellant) (Respondent) Pan: Aaace0169K Assessee By : Shri M. K. Gupta, Adv Revenue By: Shri S. K. Jadav, Cit Dr Date Of Hearing 17/07/2025 Date Of Pronouncement 08/10/2025

For Appellant: Shri M. K. Gupta, AdvFor Respondent: Shri S. K. jadav, CIT DR

Section 143(3)Section 144C(5)Section 92C

assessee is akin to the Corporate guarantee and proceeded to benchmark the same by applying Comparable Uncontrolled Price (CUP) method as the Most Appropriate Method (MAM) for determining the Arm's Length Price (ALP). The Learned TPO initially applied an average Indian bank rate of 2.23 percent

Panasonic India Private Ltd., Gurgaon vs. Neac, New Delhi

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

ITA 612/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Oct 2025AY 2016-17

Bench: Shri C. N. Prasad & Shri M. Balaganeshpanasonic India Pvt. Ltd, Vs. Neac, 12Th Floor, Ambience New Delhi Corporate Office, Tower-2, Ambience Island, Gurgaon (Appellant) (Respondent) Pan: Aadcp9391B

For Appellant: Shri Kanchan Kaushal, AdvFor Respondent: Shri S. K. Jadav, CIT (DR)

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

grossly erred in: 3.1. rejecting Resale Price Method (RPM') as adopted by the Appellant and applying Transactional Net Margin Method (TNMM') as the most appropriate method for benchmarking the international transaction; 3.2. disregarding the internal gross level comparison despite the Ld. TPO accepting that internal RPM is the more acceptable ... risk assumed by the Appellant: 3.8. disregarding the principle of consistency and not following the similar benchmarking approach i.e. RPM as the most appropriate method which had been accepted by the Ld. TPO in previous assessment years viz. for AY 2007-08 to AY 2015-16;” 4.1. We have heard

Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 901/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Oct 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

TPO/DRP erred on facts and in law in adopting a completely contradictory position of accepting Transactional Net Margin Method (TNMM') as the most appropriate method on the one hand, and yet seeking to question appropriateness of individual elements of operating cost on the other. thereby failing to appreciate fundamental ... entity wide profitability 12.5 That the TPO / DRP erred on facts and in law in rejecting Transactional Net Margin Method (TNMM) as the most appropriate method for benchmarking the international transaction of payment of royalty. 12.6 That the TPO / DRP erred on facts and in law in not following

Maruti Suzuki India Ltd., New Delhi vs. DCIT, Circle- 16(1), New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and

ITA 6949/DEL/2017[2013-14]Status: DisposedITAT Delhi08 Oct 2025AY 2013-14

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 35Section 43B

TPO/DRP erred on facts and in law in adopting a completely contradictory position of accepting Transactional Net Margin Method (TNMM)) as the most appropriate method on the one hand, and yet seeking to question appropriateness of individual elements of operating cost on the other. thereby failing to appreciate fundamental ... entity wide profitability 2.5 That the TPO / DRP erred on facts and in law in rejecting Transactional Net Margin Method (TNMM) as the most appropriate method for benchmarking the international transaction of payment of royalty. 2.6 That the TPO / DRP erred on facts and in law in not following

M/S Maruti Suzuki India Ltd., New Delhi vs. DCIT, New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and

ITA 287/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 35Section 43B

DCIT, New Delhi vs. M/S. Maruti Suzuki India Ltd., New Delhi

In the result, all the three appeals of the assessee are allowed as indicated above and the appeal of Revenue is partly allowed

ITA 1024/DEL/2016[2011-12]Status: DisposedITAT Delhi08 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri G.C. Srivastava, Spl. Counsel for the Department

Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 14ASection 32Section 35Section 43B

M/S. Tbea Shenyang Trasformer Group Company Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Int. Tax., Vadodara

Appeal is dismissed

ITA 121/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2013-14

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(2)Section 144C(5)Section 271(1)(c)Section 92BSection 92CSection 92E

comparable transaction. It is humbly submitted that without prejudice to non-applicability of provisions of Chapter X, CUP should be considered as the most appropriate method considering the arrangement between PGCIL and the Appellant. It be so held now. 7. The AO erred in fact and in law in charging ... assessee and dismissed. 5.4 Ground 6: Rejection of CUP Method 5.4.1 The assessee has further challenged the rejection of CUP as the Most Appropriate Method (MAM) for benchmarking the transactions, particularly with respect to both onshore and offshore activities. 5.4.2 This very plea was examined

Sp Armada Oil Exploration Private Limited, Mumbai vs. Deputy Commissioner of Income Tax- Circle 3(3)(1), Mumbai

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

ITA 6575/MUM/2024[2021-22]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-22

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailsp Armada Oil Exploration Private Limited 404, Trade Centre, Bandra Kurla Complex, Bandra (East), Mumbai 400051. Pan: Aaqcs7983P ............... Appellant

For Appellant: Shri Mukesh Butani a/w Shri Pratik PoddarFor Respondent: Shri. Pravin Salunkhe & Shri Aditya M. Rai

Section 143(2)Section 143(3)Section 234ASection 253(1)Section 92C(1)Section 92C(2)Section 92C(3)

payment of charter hire fees was merely a pass-through cost, and the said transaction was benchmarked using the “Other Method” as the most appropriate method. The assessee further submitted that the FPSO vessel, Armada Sterling II, is a one-of-a-kind vessel that is highly customised and built ... approach accepted by the learned DRP in assessee’s own case for assessment year 2016-17, the assessee used “Other Method” as the most appropriate method and the proportion of bareboat charter hire day rate to the time charter day rate in case of the assessee was compared with

Aptiv Components India P.Ltd (Formerly Known As Delphi Automotive Systems P.Ltd), New Delhi vs. ACIT, Circle-1(1), New Delhi

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

ITA 2082/DEL/2022[2018-19]Status: DisposedITAT Delhi01 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Anubhav Sharmam/S Aptive Components India Vs. Acit, Private Limited (Formerly Known Circle-1(1), As M/S Delphi Automotive New Delhi System Private Limited), P-24, Green Park Extension, New Delhi (Appellant) (Respondent) Pan: Aaacd0226F Assessee By : Shri Ajay Vohra, Sr. Adv Shri Neeraj Jain, Adv Ms. Richa Aggarwal, Adv Revenue By: Shri Amit Kumar Singh, Sr. Dr Date Of Hearing 04/07/2025 Date Of Pronouncement 01/10/2025

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Amit Kumar Singh, Sr. DR

Section 143(3)Section 144C(5)Section 92C

listed at pages 1 and 2 of the order of the Learned TPO dated 30-4-2021 in tabular form duly mentioning the Most Appropriate Method (MAM) applied by the assessee for each transaction. Out of the total 13 international transactions , the disputed transactions before us are with Payment ... undertaken with the associated enterprises, the assessee in its Transfer Pricing Study Report (TPSR) had applied Transactional Net Margin Method (TNMM) as the Most Appropriate Method (MAM) considering the associated enterprise (AE) as the tested party and taking the profit level indicator as Operating Profit to Operating Cost

Income Tax Officer, Jalna vs. Vikram Tea Processor Private Limited, Jalna

In the result, both the appeals filed by the Revenue are dismissed

ITA 685/PUN/2025[2013]Status: DisposedITAT Pune26 Sept 2025

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

For Appellant: Shri J P BairagraFor Respondent: Shri Basavaraj Hiremeth, Addl CIT

Section 143(2)Section 40A(2)(a)Section 92A(2)(a)Section 92BSection 92C

RENT 345000 TOTAL 1,091,880,205 3. He noted that the assessee has adopted CPM method as the most appropriate method. However, in absence of the mark-up of non-AEs, the TPO adopted internal Comparable Uncontrolled Price (CUP) method as the most appropriate method and proposed an upward ... instant case made addition of Rs.4,73,46,877/- on the basis of the TPO’s report passed u/s 92CA of the Act. We appropriate method and proposed an upward adjustment of Rs.4,73,46,877/-. We find the Ld. CIT(A) deleted the addition made by the Assessing Officer

Income Tax Officer Ward 1 Jalna, Jalna vs. Vikram Tea Processor Private Limited, Jalna

In the result, both the appeals filed by the Revenue are dismissed

ITA 2285/PUN/2024[2013]Status: DisposedITAT Pune26 Sept 2025

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

For Appellant: Shri J P BairagraFor Respondent: Shri Basavaraj Hiremeth, Addl CIT

Section 143(2)Section 40A(2)(a)Section 92A(2)(a)Section 92BSection 92C

Ebaotech India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 1(2)(1), Mumbai

In the result, the appeal is accordingly allowed for statistical purposes in above terms

ITA 6359/MUM/2024[2021-2022]Status: DisposedITAT Mumbai25 Sept 2025AY 2021-2022

Bench: The Authorities Below Are That The Assessee Is A Subsidiary Company Of The Ebao Group Which Is Globally Diversified In Insurance Software Having Its Headquarters In Shanghai, China & The Operations Of The Group Are Located In Many Countries Including India, Australia, China, Malaysia, Japan & Singapore, With Extensive Coverage In Insurance Software & Technology.

Section 115JSection 139(1)Section 142(1)Section 143(2)Section 143(3)Section 92BSection 92C

length result against which the profitability of the tested party is compared. Hence, the DRP was of the opinion that the appropriate method as per sub-section 92C(2) was the TNMM with Operating Profit/Operating Cost (OP/OC) and Operating Profit/Operating Revenue (OP/OR) as the Profit Level Indicators (PLI). Accordingly ... TNMM was held to be Most Appropriate Method to determine the ALP of the said transaction. 10 Ebaotech India Private Limited 11. Aggrieved by the impugned order, assessee is in appeal before us and has raised the following grounds of appeal:- 1) The Learned Assessment Unit, Income Tax Department

Sushee Infra & Mining Limited, Hyderabad vs. ACIT., Central Circle-2(2), Hyderabad

In the result, appeal of the Assessee is partly

ITA 1390/HYD/2024[2021-22]Status: DisposedITAT Hyderabad24 Sept 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: CA Abhiroop BhargavFor Respondent: Dr. Narendra Kumar Naik, CIT-DR

Section 143(3)Section 144C(5)Section 801ASection 801A(10)Section 92BSection 92C(3)Section 92D

Length Price [in short “ALP”] of the specified domestic transactions by adopting Transactional Net Margin Method [in short “TNMM”] as Most Appropriate Method [in short “MAM”] and then, re-calculated the profit margin of the assessee by re-apportionment of the expenses between the non-eligible and eligible infrastructure facilities ... associated enterprises (AE's) Le Sushee Arunachal Highways Limited is computed as under: Methodology : For the reasons discussed above, TVMM is taken as most appropriate method. Profit Level Indicator : Operating profit to operating cost as the Profit Level Indicator. Comparable: As discussed above Data used: Data pertaining