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


Tax Authorities Approve Shift to 'Other Method' for Arm's Length Price in Transfer Pricing Case.

June 8, 2023

Case Laws     Income Tax     AT

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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