| COURT: | ITAT Delhi |
| CORAM: | George George K (JM), R. S. Syal (AM) |
| SECTION(S): | 92CA |
| GENRE: | Transfer Pricing |
| CATCH WORDS: | CUP, Most Appropriate Method, TNMM |
| COUNSEL: | V. P. Gupta |
| DATE: | October 31, 2014 (Date of pronouncement) |
| DATE: | November 4, 2014 (Date of publication) |
| AY: | 2002-03 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| If assessee has followed CUP method, it cannot argue at the appellate stage that TNMM should be followed even if TPO has for later years accepted TNMM as the Most Appropriate Method | |
(i) It is observed that the assessee applied CUP as the most appropriate method for benchmarking the international transactions undertaken by it. The assessee did not dispute before the TPO that the CUP was the most appropriate method. However, it …
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