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The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for transfer pricing adjustment for the assessment year 2018-19. The Court noted that the ITAT had consistently held the CUP method as the most appropriate method for the same assessee in earlier years, and the Transfer Pricing Officer (TPO) erred in adopting a new method, i.e., the Transactional Net Margin Method (TNMM), treating it as the most appropriate method for the year under consideration. The High Court concurred with the ITAT's order and dismissed the revenue's appeal, holding that no substantial question of law arose.
The High Court upheld the order of the Income Tax Appellate Tribunal (ITAT) which had approved the Comparable Uncontrolled Price (CUP) method adopted by the assessee for transfer pricing adjustment for the assessment year 2018-19. The Court noted that the ITAT had consistently held the CUP method as the most appropriate method for the same assessee in earlier years, and the Transfer Pricing Officer (TPO) erred in adopting a new method, i.e., the Transactional Net Margin Method (TNMM), treating it as the most appropriate method for the year under consideration. The High Court concurred with the ITAT's order and dismissed the revenue's appeal, holding that no substantial question of law arose.
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