TP adjustment - ALP determination - Selection or change in Most ...

Case Laws     Income Tax

June 8, 2023

TP adjustment - ALP determination - Selection or change in Most Appropriate Method (MAM) - “Other Method" v/s "CUP Method" - Assessee can resile from the most appropriate method as was adopted in its transfer pricing study report - However, the MAM to benchmark the international transaction in question is the ‘Other Method’ and not the ‘CUP Method’ as per the assessee - Determination of ALP of the international transaction in question by adopting ‘Other Method’ confirmed. - AT

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