https://www.taxtmi.com/caselaws?id=369146 The ITAT remanded the case back to the AO/TPO for fresh determination, emphasizing the correct application of the Comparable Uncontrolled Price (CUP) method and consideration of comparable uncontrolled instances. The AO/TPO was directed to decide whether the payments were Cost Sharing payments or Intragroup Services. If the CUP method was not applicable, an appropriate method should be used for determining the Arm's Length Price (ALP) after hearing the appellant. The appeal was allowed for statistical purposes, with the order pronounced on 12.10.2018. en-us Fri, 12 Oct 2018 00:00:00 +0530 Sat, 20 Oct 2018 12:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=369146 The ITAT remanded the case back to the AO/TPO for fresh determination, emphasizing the correct application of the Comparable Uncontrolled Price (CUP) method and consideration of comparable uncontrolled instances. The AO/TPO was directed to decide whether the payments were Cost Sharing payments or Intragroup Services. If the CUP method was not applicable, an appropriate method should be used for determining the Arm's Length Price (ALP) after hearing the appellant. The appeal was allowed for statistical purposes, with the order pronounced on 12.10.2018. Case-Laws Income Tax Fri, 12 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=369146