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The ITAT set aside the AO's order and directed that the DRP revisit its directions regarding addition to returned income under the specified domestic transaction, in light of the amended statutory definition of "market value" and a controlling High Court decision on comparable uncontrolled price methodology. The Bench held that where an internal CUP exists it governs ALP; where no internal CUP exists, an external CUP based on distribution-company supply rates may be adopted. The AO/TPO may request the DRP to reconsider and, after examining the facts, issue modified directions for incorporation in the assessment order as warranted by law. The appeal is partly allowed for statistical purposes.
The ITAT set aside the AO's order and directed that the DRP revisit its directions regarding addition to returned income under the specified domestic transaction, in light of the amended statutory definition of "market value" and a controlling High Court decision on comparable uncontrolled price methodology. The Bench held that where an internal CUP exists it governs ALP; where no internal CUP exists, an external CUP based on distribution-company supply rates may be adopted. The AO/TPO may request the DRP to reconsider and, after examining the facts, issue modified directions for incorporation in the assessment order as warranted by law. The appeal is partly allowed for statistical purposes.
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