https://www.taxtmi.com/caselaws?id=429774 The Tribunal upheld the Ld. CIT(A)'s decisions on all grounds, dismissing the revenue's appeal. The arm's length price adjustment was deleted in favor of the internal Comparable Uncontrolled Price (CUP) method over the Transactional Net Margin Method (TNMM). The use of the CUP method was deemed appropriate for benchmarking transactions, including purchases from associated enterprises. Additionally, the deletion of the addition under "Foreign Exchange Fluctuation Loss" and the justification of purchases from allegedly bogus non-existent parties were affirmed. The order was pronounced on 2nd November 2022. en-us Wed, 02 Nov 2022 00:00:00 +0530 Fri, 04 Nov 2022 08:54:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429774 The Tribunal upheld the Ld. CIT(A)'s decisions on all grounds, dismissing the revenue's appeal. The arm's length price adjustment was deleted in favor of the internal Comparable Uncontrolled Price (CUP) method over the Transactional Net Margin Method (TNMM). The use of the CUP method was deemed appropriate for benchmarking transactions, including purchases from associated enterprises. Additionally, the deletion of the addition under "Foreign Exchange Fluctuation Loss" and the justification of purchases from allegedly bogus non-existent parties were affirmed. The order was pronounced on 2nd November 2022. Case-Laws Income Tax Wed, 02 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429774