https://www.taxtmi.com/highlights?id=70425 Transfer Pricing Adjustments - benchmarking the purchase of SIM cards by the assessee from its AEs - selection of MAM - CUP v/s RPM - CIT(A) has incorrectly applied the CUP method based on incomplete data, ignoring geographical differences and contrary to the Assessee’s own TP Analysis and contrary to TP Auditor’s Report. CIT(A) has also erroneously aggregated the transactions despite judicial pronouncements on the issue. - AT en-us Mon, 19 Jun 2023 10:19:32 +0530 Mon, 19 Jun 2023 10:19:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=70425 Transfer Pricing Adjustments - benchmarking the purchase of SIM cards by the assessee from its AEs - selection of MAM - CUP v/s RPM - CIT(A) has incorrectly applied the CUP method based on incomplete data, ignoring geographical differences and contrary to the Assessee’s own TP Analysis and contrary to TP Auditor’s Report. CIT(A) has also erroneously aggregated the transactions despite judicial pronouncements on the issue. - AT Highlights Income Tax Mon, 19 Jun 2023 10:19:32 +0530 https://www.taxtmi.com/highlights?id=70425