High Court Overrules Tribunal: Stresses Consistent Application of TNMM or CUP for Transfer Pricing Adjustments.

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....TP Adjustment - MAM for Royalty payment - Having accepted the TNMM method as the most appropriate, it was not open to the TPO to subject only one element, i.e, payment of royalty, to an entirely different CUP method. - The Tribunal (ITAT) was not justified in taking a different view for these three assessment orders. - HC....