High Court Finds TNMM More Appropriate than CUP Transfer Pricing Method

This case note reviews the Bombay High Court’s finding in Principal Commissioner of Income Tax v. Amphenol Interconnect Private Ltd that the transactional net margin method was a more appropriate method than the comparable uncontrolled price method to determine the arm’s length price of goods traded, and commission payments made, between associated parties, due to differences in the volume of goods sold, geographical markets, timing and other functional factors.