Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Transfer pricing benchmarking under the Comparable Uncontrolled Price method turned on whether commodity broker quotations from Sunvin Group and MMSPL could be treated as reliable external CUP data. The Tribunal, following earlier Delhi High Court and ITAT decisions, held that such quotations are valid where they relate to the actual transaction, are publicly available, and no material casts doubt on their authenticity or reliability. On that basis, rejection of the quotations was unsustainable, the assessee's challenge succeeded, and the transfer pricing adjustment was deleted; the remaining connected grounds became infructuous.
Transfer pricing benchmarking under the Comparable Uncontrolled Price method turned on whether commodity broker quotations from Sunvin Group and MMSPL could be treated as reliable external CUP data. The Tribunal, following earlier Delhi High Court and ITAT decisions, held that such quotations are valid where they relate to the actual transaction, are publicly available, and no material casts doubt on their authenticity or reliability. On that basis, rejection of the quotations was unsustainable, the assessee's challenge succeeded, and the transfer pricing adjustment was deleted; the remaining connected grounds became infructuous.
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