https://www.taxtmi.com/caselaws?id=463501 ITAT-Bang held that the transfer-pricing officer and DRP rightly rejected the CUP method for lack of evidence that purchases from AE and non-AE were for identical products; adoption of TNMM as MAM was sustained. Several comparables were examined: one semiconductor firm was held functionally comparable; multiple companies (including Centum/Continental/other named comparables) were remanded to the TPO/AO for fresh verification of product comparability or related-party transactions; several comparables were affirmed as non-comparable. Parties are free to locate alternative comparables in remand proceedings. en-us Fri, 27 Nov 2015 00:00:00 +0530 Thu, 04 Sep 2025 19:12:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463501 ITAT-Bang held that the transfer-pricing officer and DRP rightly rejected the CUP method for lack of evidence that purchases from AE and non-AE were for identical products; adoption of TNMM as MAM was sustained. Several comparables were examined: one semiconductor firm was held functionally comparable; multiple companies (including Centum/Continental/other named comparables) were remanded to the TPO/AO for fresh verification of product comparability or related-party transactions; several comparables were affirmed as non-comparable. Parties are free to locate alternative comparables in remand proceedings. Case-Laws Income Tax Fri, 27 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463501