https://www.taxtmi.com/caselaws?id=800387 Comparable Uncontrolled Price Method permits direct comparison with an uncontrolled transaction where identical raw materials are supplied by an unrelated vendor. Where an associated enterprise merely intermediates, adds no value, and its mark-up is reversed through credit notes so that the effective purchase price matches the vendor price, CUP is the appropriate method. Transactional Net Margin Method and retained comparables are not justified on those facts. Including omitted operating revenue under DRP directions would also remove the proposed adjustment. Accordingly, no arm's-length price adjustment is warranted for such routed raw-material purchases. en-us Tue, 15 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800387 Comparable Uncontrolled Price Method permits direct comparison with an uncontrolled transaction where identical raw materials are supplied by an unrelated vendor. Where an associated enterprise merely intermediates, adds no value, and its mark-up is reversed through credit notes so that the effective purchase price matches the vendor price, CUP is the appropriate method. Transactional Net Margin Method and retained comparables are not justified on those facts. Including omitted operating revenue under DRP directions would also remove the proposed adjustment. Accordingly, no arm's-length price adjustment is warranted for such routed raw-material purchases. Case-Laws Income Tax Tue, 15 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800387