CUP Method Deemed Inappropriate for Assessee; Adjustments for Arm's Length Price Unjustified and Not Required.

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....TPA - The CUP method is not the most appropriate method in the case of the assessee since suitable adjustments are not possible to be made in respect of the above differences. So, the addition on this account is not justified. No adjustment is to be made for determining the arm's length price - AT....