TP Adjustment - ALP of International Transactions of import of ...

Transfer Pricing Officer's CUP Method Invalidated Due to Lack of Comparable Transactions; Additions Deleted.

November 30, 2023

Case Laws Income Tax AT

TP Adjustment - ALP of International Transactions of import of fixed assets - Even though the Ld. TPO had mentioned that he is following CUP method as the most appropriate method for benchmarking this transaction, in effect, he had not adopted CUP method as per Rule 10B of the Rules. This is because of the fact that he had not brought on record any comparable uncontrolled transactions to justify the basis of adoption under CUP. - Additions deleted - AT

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TP Adjustment - ALP of International Transactions of import of ...

Transfer Pricing Officer's CUP Method Invalidated Due to Lack of Comparable Transactions; Additions Deleted.

November 30, 2023

Case Laws Income Tax AT

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