Matter remanded as TPO adopted TNMM to determine ALP at entity level instead of at transaction level

IT/ILT : Where assessee, engaged in freight forwarding services, adopted Profit Split Method for cost collection received and cost collections paid in order to determine ALP of international transactions with its AEs without doing bench making with reliable external market data and, at same time, TPO also adopted TNMM incorrectly at entity level in order to make some adjustment to assessee's ALP, impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh