Transfer Pricing Case Rejects CUP Method for Export Pricing Due to Geographical Differences Impacting Arm's Length Price Assessment.

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....TP adjustment in export of finished goods to AE - comparison of the price charged to non–AEs located in India with the price charged to AEs in foreign countries cannot be considered to be a CUP to determine the ALP being situated in different geographical locations, as there may be various factors/reasons which could have influenced the price charged - CUP rejected....