TMI Blog2025 (3) TMI 236X X X X Extracts X X X X X X X X Extracts X X X X ..... M or CUP - as decided by HC [2023 (8) TMI 458 - BOMBAY HIGH COURT] wherein as concur with Appellant that having accepted the TNMM method as the most appropriate, it was not open to the TPO to subject only one element, i.e, payment of royalty, to an entirely different CUP method. HELD THAT:- It is stated that the tax effect is less than ₹5 crores; hence, the Revenue would not press the prese ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... an ₹5 crores; hence, the Revenue would not press the present special leave petition.
In view of the statement made, the special leave petition is dismissed as not pressed, leaving the question(s) of law open.
In view of the aforesaid order, we are not examining the application for condonation of the delay.
Pending application(s), if any, shall stand disposed of. X X X X Extracts X X X X X X X X Extracts X X X X
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