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 age

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