https://www.taxtmi.com/caselaws?id=204792 ITAT, MUMBAI - AT held that for determining ALP on euro-denominated trade credit to an AE the CUP method cannot use AE-to-AE transactions as comparables; internal CUP comparables must involve the assessee and an independent party, while external CUPs are between independent parties. On the facts the tribunal allowed relief to the assessee on the ALP interest issue. The tribunal also upheld deduction under s.10A relying on precedent favorable to the assessee. The appeal was dismissed. en-us Thu, 30 Jun 2011 00:00:00 +0530 Wed, 03 Jun 2026 15:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=204792 ITAT, MUMBAI - AT held that for determining ALP on euro-denominated trade credit to an AE the CUP method cannot use AE-to-AE transactions as comparables; internal CUP comparables must involve the assessee and an independent party, while external CUPs are between independent parties. On the facts the tribunal allowed relief to the assessee on the ALP interest issue. The tribunal also upheld deduction under s.10A relying on precedent favorable to the assessee. The appeal was dismissed. Case-Laws Income Tax Thu, 30 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=204792