https://www.taxtmi.com/caselaws?id=440238 HC dismissed the appeal and upheld the ITAT and CIT(A) findings that the TPO's application of the CUP method for benchmarking the international transactions was unwarranted. Because the comparables used by the TPO were negligible and the CPM method previously applied by the taxpayer had been accepted by the TPO in later years and in assessments on record, the TP adjustments based on CUP and the alternative internal rate of return were rejected. No substantial question of law arises. en-us Wed, 28 Jun 2023 00:00:00 +0530 Sat, 25 Oct 2025 13:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440238 HC dismissed the appeal and upheld the ITAT and CIT(A) findings that the TPO's application of the CUP method for benchmarking the international transactions was unwarranted. Because the comparables used by the TPO were negligible and the CPM method previously applied by the taxpayer had been accepted by the TPO in later years and in assessments on record, the TP adjustments based on CUP and the alternative internal rate of return were rejected. No substantial question of law arises. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440238