In subsequent assessment years, assessee benchmarked import of finished goods from AE by applying TNMM. The Transfer Pricing Officer has also accepted it as most appropriate method. The same comparables, as selected in impugned assessment year are accepted as good comparables in subsequent assessment years. The deletion of addition is held to be justified. (AY. 2007-08)
Dy.CIT v. India Medtronic Pvt. Ltd. (2020) 205 TTJ 950 (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-No other method is applicable-TNMM has to be applied as most appropriate method-Deletion of addition is held to be justified.