Transfer Pricing Adjustment: Authorities' Use of CUP Method Deemed Unsustainable Due to Differences Between AE and Non-AE Sales.

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....TP Adjustment - benchmarking export of finished goods to associated enterprises - There are significant differences in the sales made by the assessee to its AEs and non-AEs, the effect of which has neither been given by the TPO nor it has been shown that how it can be given, we hold that the action of the authorities below in applying the CUP as the most appropriate method cannot be sustained. - AT....