https://www.taxtmi.com/caselaws?id=350706 The High Court upheld the Tribunal's decision regarding the application of the Comparable Uncontrolled Prices Method (CUP) in international transactions, emphasizing the need to explain transactions using the selected method. The court affirmed the adjustments made by the authorities within the framework of the Income Tax Act and rules, rejecting the appellant's contentions related to advance consideration, discounts, and the use of Transactional Net Margin Method (TNMM). The Tribunal's emphasis on rational explanations for discounts offered in business transactions was supported, with the court requiring transactions to be justified within the context of the chosen method, i.e., CUP. en-us Mon, 06 Nov 2017 00:00:00 +0530 Fri, 10 Nov 2017 10:24:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=350706 The High Court upheld the Tribunal's decision regarding the application of the Comparable Uncontrolled Prices Method (CUP) in international transactions, emphasizing the need to explain transactions using the selected method. The court affirmed the adjustments made by the authorities within the framework of the Income Tax Act and rules, rejecting the appellant's contentions related to advance consideration, discounts, and the use of Transactional Net Margin Method (TNMM). The Tribunal's emphasis on rational explanations for discounts offered in business transactions was supported, with the court requiring transactions to be justified within the context of the chosen method, i.e., CUP. Case-Laws Income Tax Mon, 06 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=350706