TMI BlogTransfer Pricing Officers Adjust ALP Using CUP Method for Transactions with Japanese Company Due to Unusual Features.Transfer pricing adjustment - the unusual features which remained unexplained by the assessee, influenced the TPO and the AO to resort to transfer pricing adjustment and determine ALP by adopting the CUP method for the procurements from Sumitomo Japan. - HC ..... X X X X Extracts X X X X X X X X Extracts X X X X
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