TNMM is most appropriate method for determining ALP for payment of license & management fees

Bostik India Private Limited Vs DCIT (ITAT Bangalore) Facts- The assessee company is a wholly owned subsidiary of Bostik Australia Pvt. Ltd. which in turn is part of the `Bostik International Group’. For the AY 2011-2012 to 2013-2014, the assessments were selected for scrutiny and as there were international transactions with Associated Enterprises (AEs), the Assessing Officer referred the matter under provisions of section 92CA(1) to the Transfer Pricing Officer (TPO) to determine the Arm’s Length Price (ALP) in respect of such transactions. The assessee submitted before the TPO that thes...