https://www.taxtmi.com/highlights?id=57223 TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different geographical markets as compared to the market in which the controlled transactions is undertaken.t is crystal clear that the assessee's transactions are with overseas FIIs and hence comparison with other overseas FIIs would alone be appropriate. The fact remains that domestic third party transactions are not comparable with the overseas FIIs on account of geographic differences. - AT en-us Thu, 18 Mar 2021 15:21:11 +0530 Thu, 18 Mar 2021 15:21:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=57223 TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different geographical markets as compared to the market in which the controlled transactions is undertaken.t is crystal clear that the assessee's transactions are with overseas FIIs and hence comparison with other overseas FIIs would alone be appropriate. The fact remains that domestic third party transactions are not comparable with the overseas FIIs on account of geographic differences. - AT Highlights Income Tax Thu, 18 Mar 2021 15:21:11 +0530 https://www.taxtmi.com/highlights?id=57223