Court Rejects CUP Method in Transfer Pricing Case, Suggests TNMM Due to Data Insufficiency and Transaction Differences.

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....TPA - MAM selection - CUP or TNMM - if the intra AE transactions were fundamentally different in character in economic circumstances and contractual terms then these cannot be compared with the independent transactions entered into by the assessee - the availability, coverage and reliability of data necessary for application of the method - CUP rejected....