CUP Method Rejected for Transfer Pricing; AO Directed to Use TNMM for Benchmarking International Transactions Margins.
X X X X Extracts X X X X
X X X X Extracts X X X X
....Transfer pricing adjustment - most appropriate method - CUP method was not correct method - AO directed to apply TNMM method to benchmark the international transactions of assessee and compare the margins shown by assessee with the mean margins of comparables which are functionally comparable.....
TaxTMI