Tribunal held that , Transactional net margin method is most appropriate method in respect of professional consultancy fees, management fees for support service and sap consultancy charges .Accordingly the AO was directed to delete the addition. ( AY.2007 -08)
Knorr Bremse India P. Ltd. v. ACIT (2018) 65 ITR 15 (SN) (Delhi) (Trib)
S. 92C : Transfer pricing – Arm’s length price -Professional consultancy fees, management fees for support service and sap consultancy charges — Transactional net margin method is most appropriate method.