Court Rules Transfer Pricing Adjustment Unsupported Due to FAR Differences; CUP Method Lacks Justification Over TNMM Use.

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....TP adjustment - without factoring in the difference in FAR, the comparison done by the TPO is not sustainable - there is no proper reason to apply CUP method, instead of that consistently applied earlier method of TNMM, as the most appropriate method (MAM).....