TNMM is a right method to arrive at ALP when assessee have not taken Substantial Risks

Brief of the Case In the present facts of the case the Hon’ble High Court held that as the assessee have not taken substantial risks and was a mediator in the international transactions. Hence, Transactional Net Margin Method is a right method instead of Profit Split method. Facts of the Case The brief facts of the case are that the assessee is a wholly owned subsidiary of a foreign company and provides agency services on behalf of it and other group companies across the globe and also liaises between departments of group companies and their suppliers/customers in India. For AY 2008-09, five...