TNMM is most appropriate method if transactions are relatable & inter­related

Wieland Metals India Private Ltd. Vs ITO (ITAT bangalore) Issue before us is with regard to TP adjustment by applying TNMM by the TPO instead of CUP method adopted by the assessee as most appropriate method in respect of determining of ALP of manufacturing segment. As seen from the details of international transactions, the assessee is importing raw material from its AE and also making exports of products to the customers in accordance with the Purchase Order which is carried out by Wieland group. Thus, import as well as export transactions are interlinked and closely linked. The price of expo...