https://www.taxtmi.com/highlights?id=36236 When direct CUP between the AE and Tata Communications from whom the assessee has taken the network on lease is available then the ALP has to be computed under CUP - However, when the assessee has expressed its helplessness to compute the margins separately in respect of the international transactions then the direct CUP available in case of the assessee would be an appropriate method of determination of ALP. en-us Wed, 06 Sep 2017 17:52:00 +0530 Wed, 06 Sep 2017 17:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=36236 When direct CUP between the AE and Tata Communications from whom the assessee has taken the network on lease is available then the ALP has to be computed under CUP - However, when the assessee has expressed its helplessness to compute the margins separately in respect of the international transactions then the direct CUP available in case of the assessee would be an appropriate method of determination of ALP. Highlights Income Tax Wed, 06 Sep 2017 17:52:00 +0530 https://www.taxtmi.com/highlights?id=36236