TP Adjustment - MAM - Management consultancy services - The ...

Tribunal Upholds Use of CUP Method for Valuing Consultancy Services, Overrules TPO's Preference for TNMM.

May 7, 2024

Case Laws Income Tax AT

TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices.

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TP Adjustment - MAM - Management consultancy services - The ...

Tribunal Upholds Use of CUP Method for Valuing Consultancy Services, Overrules TPO's Preference for TNMM.

May 7, 2024

Case Laws Income Tax AT

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