https://www.taxtmi.com/caselaws?id=472420 Comparable Uncontrolled Price (CUP) is the most appropriate method for benchmarking subcontracting services received from an associated enterprise where relevant-year metrics materially match an earlier year in which CUP was accepted; consistency and certainty support its retention over TNMM. Section 43B does not permit disallowance of an unpaid service-tax liability when the provision has not been claimed as expenditure or deduction, because no corresponding deduction exists to disallow. The transfer-pricing adjustment is removed and the service-tax adjustment deleted. en-us Mon, 31 May 2021 00:00:00 +0530 Mon, 12 Oct 2026 16:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472420 Comparable Uncontrolled Price (CUP) is the most appropriate method for benchmarking subcontracting services received from an associated enterprise where relevant-year metrics materially match an earlier year in which CUP was accepted; consistency and certainty support its retention over TNMM. Section 43B does not permit disallowance of an unpaid service-tax liability when the provision has not been claimed as expenditure or deduction, because no corresponding deduction exists to disallow. The transfer-pricing adjustment is removed and the service-tax adjustment deleted. Case-Laws Income Tax Mon, 31 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472420