TPO's Comparison of Export and Domestic Margins Deemed Unjustified Due to Market Differences; CMA Method Unsuitable for ALP.

Transfer pricing (TP) adjustment - the learned TPO was not justified in comparing the gross margin in export segment vis-a-vis gross margins in domestic segment. - There are different characteristics and contractual terms in the two segments and further geographical and marked differences are also present. Thus, we are of the view that it is very difficult to make suitable adjustments for these differences, hence the CMA method is not appropriate method for determining the ALP - AT .....

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