Transfer Pricing – Transactional Net Margin Method (TNMM) At Enterprise Level Invalid

Symantec software Solutions Pvt Ltd Vs. ACIT (ITAT Mumbai)- The burden of proving that the transactions with the Assocciated Enterprises is at arms’ length is on the assessee. If the Transactional Net Margin Method (TNMM) is adopted, the comparison has to be made between the net margin realized from the operation of the uncontrolled parties’ transaction and net margin derived by the assessee on similar international transactions. The comparison should be between the net margins on transaction basis and not at enterprise level.

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