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Home Highlights December 2022 Year 2022 This

TP Adjustment - the TPO is erred in adopting CUP method for few ...


TPO's Misuse of CUP Method Overturned; DRP's Oversight Corrected, AO and TPO to Remove Adjustments.

December 14, 2022

Case Laws     Income Tax     AT

TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP without appreciating the above facts, simply sustained TP adjustment suggested by the TPO. Hence, we direct the AO/TPO to delete TP adjustment made towards few transactions by adopting CUP as most appropriate method. - AT

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