Transfer Pricing Officer's stance on averaging costs under CUP method contradicts Section 92C(2) & Rule 10B(1)(a) of IT Rules.

Transfer Pricing Officer's stance on averaging costs under CUP method contradicts Section 92C(2) & Rule 10B(1)(a) of IT Rules. https://www.taxtmi.com/highlights?id=66366 Arm’s length price adjustment - CIT(A) held that observations of the TPO’s that averaging of cost of purchases was not permissible under CUP method is in contradiction to the provision contained in Section 92C(2) read with Rule 10B(1)(a) of the Income Tax Rules, 1962 wherein it has been explicitly provided that where more than one uncontrolled transactions or prices are available then the ALP shall be the arithmetic mean of such prices. - AT en-us Fri, 04 Nov 2022 14:39:17 +0530 Fri, 04 Nov 2022 14:39:17 +0530 TaxTMI RSS Generator Transfer Pricing Officer's stance on averaging costs under CUP method contradicts Section 92C(2) & Rule 10B(1)(a) of IT Rules. https://www.taxtmi.com/highlights?id=66366 Arm’s length price adjustment - CIT(A) held that observations of the TPO’s that averaging of cost of purchases was not permissible under CUP method is in contradiction to the provision contained in Section 92C(2) read with Rule 10B(1)(a) of the Income Tax Rules, 1962 wherein it has been explicitly provided that where more than one uncontrolled transactions or prices are available then the ALP shall be the arithmetic mean of such prices. - AT Highlights Income Tax Fri, 04 Nov 2022 14:39:17 +0530 https://www.taxtmi.com/highlights?id=66366