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ITAT ruled that CUP method was inapplicable for transfer pricing adjustment due to fundamental differences not reasonably adjustable, holding TNMM as most appropriate method under Rule 10C(2) read with Rule 10B(1)(e). The assessee obtained license from international breeder for specialized potato cultivation, while the related entity merely coordinated contract farming activities. ITAT determined the related entity as tested party being a simple trader without intangibles, versus assessee as complex entity possessing know-how. Purchase transactions at cost-plus markup were held at arm's length based on comparable margins from reliable databases. Transfer pricing adjustment was deleted, rendering penalty proceedings under sections 270A and 271AA infructuous. Matter regarding book profits computation under section 115JB was remanded for verification and appropriate relief.
ITAT ruled that CUP method was inapplicable for transfer pricing adjustment due to fundamental differences not reasonably adjustable, holding TNMM as most appropriate method under Rule 10C(2) read with Rule 10B(1)(e). The assessee obtained license from international breeder for specialized potato cultivation, while the related entity merely coordinated contract farming activities. ITAT determined the related entity as tested party being a simple trader without intangibles, versus assessee as complex entity possessing know-how. Purchase transactions at cost-plus markup were held at arm's length based on comparable margins from reliable databases. Transfer pricing adjustment was deleted, rendering penalty proceedings under sections 270A and 271AA infructuous. Matter regarding book profits computation under section 115JB was remanded for verification and appropriate relief.
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