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CUP method couldn't be used for benchmarking if there was difference in pricing factors due to diff. in market

November 27, 2018[2018] 99 taxmann.com 319 (Delhi - Trib.)
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IT/ILT: Different market and geographical location also affect pricing factors and therefore, if there were differences on account of these factors CUP could not have been held to be most appropriate method for benchmarking arm's length price

IT/ILT: TNMM was to be accepted as most appropriate method to determine ALP of international transaction of indent sales, keeping into fact that assessee engaged in indent sales was a low risk service provider and there was no change in FAR right from assessment years 2003-04 to 2018-19

IT/ILT: In case of assessee engaged in indent sales, being a low risk service provider, operating expenses adequately and sufficiently represent functions performed and risk undertaken by assessee; hence, 'berry ratio' was to be accepted as most appropriate PLI for taking as base under TNMM while determining ALP

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