Court Upholds TNMM Over CUP for Transfer Pricing; TNMM Deemed Most Accurate Under Similar FAR Conditions.

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....TP Adjustment - MAM selection - once TNMM has been accepted under the similar FAR, there is no reason to deviate by adopting CUP Method and other methods admittedly are incapable of capturing the true arm's length result and therefore, we hold that TNMM should be taken as a most appropriate method for benchmarking the said transaction. - AT....