Transfer Pricing Officer's Method Deemed Inappropriate: Flawed Comparisons and CUP Method Misuse in Chemical Transactions.

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....Transfer pricing (TP) adjustments - The method adopted by the TPO suffered from the defect of the comparing uncomparable chemicals, using an average variation between the ALP and the actual price in two different chemicals, using the same as the variation in the ALP of the ten different chemicals. - We are of the view that the CUP method suffered from multiple infirmities and was not a most appropriate method for the transactions pertaining to the year under consideration. - AT....