https://www.taxtmi.com/caselaws?id=790479 Comparable uncontrolled price benchmarking for potato purchases from an associated enterprise failed because the controlled and uncontrolled transactions involved material differences in quality, volume, contractual terms and business model, with no reliable adjustments shown to remove those differences. Following the coordinate bench ruling in the assessee's own earlier year, the Tribunal held that the transactional net margin method was the appropriate method once CUP was unsustainable, and treated the associated enterprise as the least complex and proper tested party. The assessee's TNMM benchmarking was therefore accepted and the transfer pricing adjustment was deleted. en-us Wed, 22 Apr 2026 00:00:00 +0530 Sat, 25 Apr 2026 08:51:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790479 Comparable uncontrolled price benchmarking for potato purchases from an associated enterprise failed because the controlled and uncontrolled transactions involved material differences in quality, volume, contractual terms and business model, with no reliable adjustments shown to remove those differences. Following the coordinate bench ruling in the assessee's own earlier year, the Tribunal held that the transactional net margin method was the appropriate method once CUP was unsustainable, and treated the associated enterprise as the least complex and proper tested party. The assessee's TNMM benchmarking was therefore accepted and the transfer pricing adjustment was deleted. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790479