TP Adjustment - selection of MAM - CUP cannot be applied on ...

CUP Method Inapplicable for Transfer Pricing Between Different Geographical Markets; Overseas FIIs Must Be Compared with Overseas FIIs Only.

March 18, 2021

Case Laws Income Tax AT

TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different geographical markets as compared to the market in which the controlled transactions is undertaken.t is crystal clear that the assessee's transactions are with overseas FIIs and hence comparison with other overseas FIIs would alone be appropriate. The fact remains that domestic third party transactions are not comparable with the overseas FIIs on account of geographic differences. - AT

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TP Adjustment - selection of MAM - CUP cannot be applied on ...

CUP Method Inapplicable for Transfer Pricing Between Different Geographical Markets; Overseas FIIs Must Be Compared with Overseas FIIs Only.

March 18, 2021

Case Laws Income Tax AT

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