Decision that internal TNMM is preferred over external TNMM

The Income Tax Appellate Tribunal (ITAT) issued its decision on 29 January 2013 in the case of Genisys Integrating System (I) Pvt Ltd v. DCIT (ITA No.908 /Bang/2011) that an internal transactional net margin method (TNMM) ought to be selected as the most appropriate method for determining the arm's length price for software services as against an external TNMM where similar services were provided to associated and non-associated enterprises, and reliable internal data was available. The ITAT rel…