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Court Rejects TNMM for Brokerage Income Transfer Pricing; Prefers Internal CUP Method for Fairness in AE Transactions.

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....TP Adjustment - adjustment of brokerage income - assessee also filed submission before the TPO providing detailed explanation with regard to the differences in services provided to the AE and Non-AEs and explanation in support that TNMM was the most appropriate method to determine the ALP of brokerage earned from AEs. - No merit in the submission that TNMM is the correct method and internal CUP would entail adhoc adjustment to price in so far as broking commission from AE and Non AEs are concerned.....

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Court Rejects TNMM for Brokerage Income Transfer Pricing; Prefers Internal CUP Method for Fairness in AE Transactions.