https://www.taxtmi.com/caselaws?id=184191 For transfer pricing purposes, arm's length price must be benchmarked against a comparable uncontrolled transaction, not against another controlled transaction between associated enterprises. The Tribunal held that commission rates accepted in one associated-enterprise transaction could not be used as an internal CUP for a separate related-party transaction, because the statutory CUP method requires an external uncontrolled comparison. Applying the Third Member view relied on, the Tribunal sustained the restriction of the addition and rejected the Revenue's challenge to the reduction made by the Commissioner (Appeals). en-us Fri, 18 Jan 2013 00:00:00 +0530 Fri, 01 Jul 2016 17:38:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184191 For transfer pricing purposes, arm's length price must be benchmarked against a comparable uncontrolled transaction, not against another controlled transaction between associated enterprises. The Tribunal held that commission rates accepted in one associated-enterprise transaction could not be used as an internal CUP for a separate related-party transaction, because the statutory CUP method requires an external uncontrolled comparison. Applying the Third Member view relied on, the Tribunal sustained the restriction of the addition and rejected the Revenue's challenge to the reduction made by the Commissioner (Appeals). Case-Laws Income Tax Fri, 18 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184191