CUP Method Deemed Best for Arm's Length Price in Transfer Pricing Case; Party Must Provide Independent Study Evidence.

Transfer pricing adjustment - CUP method as the Most Appropriate Method for determination of ALP for international transactions. The assessee is also directed to furnish the comparables based on independent TP study for adoption of CUP method and produce such other evidences and documents before the Learned TPO / AO to ensure quick disposal of this set aside proceedings. - AT .....

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