TNMM Most Appropriate Method in case of AE transactions

Toyota Boshoku Automotive India Pvt. Ltd Vs ACIT (ITAT Bangalore) Held that assessee leverages on the use of technology from the AE and does not contribute any unique intangibles to the transaction. PSM cannot be applied. TNM Method is Most Appropriate Method. Facts- The appellant is engaged in the business of manufacturing automobile component such as seats, door strings, and interiors for the automobile industry. During the course of scrutiny proceedings, it has been observed that the company had entered into several international transactions with its associated enterprises. The case was re...