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TNMM is most appropriate method for benchmarking international transactions of payment of FTS

September 26, 2019[2019] 109 taxmann.com 182 (Mumbai - Trib.)
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TRANSFER PRICING: Where Tribunal in assessee's own case for earlier assessment years held that for benchmarking international transactions of payment of fees for technical assistance services TNM method was MAM and restored issue for verification as to whether margin of tested party was at arm's length to margins of comparables companies, in absence of change in circumstances for year under consideration, matter was to be restored back to TPO for disposal afresh with similar directions

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