https://www.taxtmi.com/caselaws?id=797006 Comparable Uncontrolled Price method is appropriate where reliable internal and external data for identical raw materials show that associated-enterprise prices are no higher than independent-supplier and relevant import prices. Consistent acceptance of that method on unchanged transaction and business facts supports its continued application, while replacing it with the Transactional Net Margin Method would breach consistency. Even under TNMM, a diversified manufacturer and service provider without segmental financial data is not functionally comparable to an entity manufacturing only optical fibre. The assessee's arm's length price determination was upheld and the transfer-pricing adjustment was deleted. en-us Fri, 07 Aug 2026 00:00:00 +0530 Fri, 14 Aug 2026 07:18:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797006 Comparable Uncontrolled Price method is appropriate where reliable internal and external data for identical raw materials show that associated-enterprise prices are no higher than independent-supplier and relevant import prices. Consistent acceptance of that method on unchanged transaction and business facts supports its continued application, while replacing it with the Transactional Net Margin Method would breach consistency. Even under TNMM, a diversified manufacturer and service provider without segmental financial data is not functionally comparable to an entity manufacturing only optical fibre. The assessee's arm's length price determination was upheld and the transfer-pricing adjustment was deleted. Case-Laws Income Tax Fri, 07 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797006