https://www.taxtmi.com/highlights?id=77209 TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices. en-us Tue, 07 May 2024 09:42:47 +0530 Tue, 07 May 2024 09:42:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=77209 TP Adjustment - MAM - Management consultancy services - The tribunal noted discrepancies in how services were valued between Associated Enterprises (AE) and Non-AEs. The CUP method was initially rejected by the TPO in favor of TNMM, citing lack of stringent comparability. However, the tribunal supported the appellant's use of CUP, observing that internal comparables provided a reasonable basis for determining arm's length prices. Highlights Income Tax Tue, 07 May 2024 09:42:47 +0530 https://www.taxtmi.com/highlights?id=77209