https://www.taxtmi.com/caselaws?id=763048 CUP was preferred for benchmarking the assessee's international transactions because it had been consistently applied in earlier and later years, and no material change in facts justified switching to TNMM. The discussion notes that bona fide quotations may support CUP where they are reliable and comparable, and that an arm's length price need not depend only on an actually executed uncontrolled transaction. Jai Hind Projects Ltd. was treated as functionally dissimilar, given its large infrastructure and pipeline projects compared with the assessee's design and construction work, so it was not a proper comparable and had to be excluded. en-us Wed, 29 May 2024 00:00:00 +0530 Wed, 11 Dec 2024 18:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763048 CUP was preferred for benchmarking the assessee's international transactions because it had been consistently applied in earlier and later years, and no material change in facts justified switching to TNMM. The discussion notes that bona fide quotations may support CUP where they are reliable and comparable, and that an arm's length price need not depend only on an actually executed uncontrolled transaction. Jai Hind Projects Ltd. was treated as functionally dissimilar, given its large infrastructure and pipeline projects compared with the assessee's design and construction work, so it was not a proper comparable and had to be excluded. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763048