https://www.taxtmi.com/caselaws?id=310413 TIPS-based external CUP benchmarking was found unreliable for the assessee's export transactions because the goods involved different iron-content grades, different ports, and other material differences that made direct comparison unsafe. The data also did not capture all relevant transactions or adjust for conditions affecting price, so the external CUP exercise was faulty. Benchmarking against the assessee's own non-AE exports was treated as the more appropriate internal comparable method because transfer pricing requires controlled transactions to be tested against reasonably similar uncontrolled transactions. The DRP's direction to use internal comparables was upheld, and the Revenue's challenge to the transfer pricing adjustment failed. en-us Fri, 19 Jan 2018 00:00:00 +0530 Tue, 24 Oct 2023 10:31:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310413 TIPS-based external CUP benchmarking was found unreliable for the assessee's export transactions because the goods involved different iron-content grades, different ports, and other material differences that made direct comparison unsafe. The data also did not capture all relevant transactions or adjust for conditions affecting price, so the external CUP exercise was faulty. Benchmarking against the assessee's own non-AE exports was treated as the more appropriate internal comparable method because transfer pricing requires controlled transactions to be tested against reasonably similar uncontrolled transactions. The DRP's direction to use internal comparables was upheld, and the Revenue's challenge to the transfer pricing adjustment failed. Case-Laws Income Tax Fri, 19 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310413