https://www.taxtmi.com/caselaws?id=209698 Arm's length pricing for an international transaction should not be fixed by mechanically comparing the assessee's rate with that of a much larger independent concern where the factual position is materially different. The text states that, for a newer and dependent service provider, a reliable comparable must be selected and the price may, if necessary, be derived by reference to the subsequent year's rate with an appropriate inflationary adjustment. Once such a discounted CUP-based rate is worked out, no further ad hoc reduction is warranted. The arm's length price was to be redetermined under the CUP method, and the cited comparable was not accepted. en-us Fri, 15 Jul 2011 00:00:00 +0530 Mon, 06 Feb 2012 22:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=209698 Arm's length pricing for an international transaction should not be fixed by mechanically comparing the assessee's rate with that of a much larger independent concern where the factual position is materially different. The text states that, for a newer and dependent service provider, a reliable comparable must be selected and the price may, if necessary, be derived by reference to the subsequent year's rate with an appropriate inflationary adjustment. Once such a discounted CUP-based rate is worked out, no further ad hoc reduction is warranted. The arm's length price was to be redetermined under the CUP method, and the cited comparable was not accepted. Case-Laws Income Tax Fri, 15 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=209698