TNMM is best Method to benchmark international transactions with AE

DCIT Vs Knorr Bremse India Pvt. Ltd. (ITAT Delhi)

TNMM is the Most Appropriate Method to benchmark the international transactions entered into by the taxpayer with its AE qua professional consultancy services (information technology) and fee for management support services but TPO, for the reasons best known to him and to our mind to generate unnecessary litigation, proceeded to apply the CUP method by applying same reasoning applied in the earlier years.

So, ld. CIT (A) has rightly deleted the additions by following

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