Choosing the Most Appropriate Method for Arm's Length Price: CUP vs. TNMM in Transfer Pricing, Rule 10B(1)(a)(i.

Transfer pricing - determination of ALP - selection of MAM - application of CUP method as against TNMM - AO/TPO directed first apply CUP using some comparable instances following Rule 10B(1)(a)(i) and in the eventuality the TPO comes to the conclusion that the relevant data is not available, he is free to select any appropriate method for fresh determination of ALP after hearing the assessee. .....

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