Allowing the appeal the Tribunal held that CUP method is not the most appropriate method in the facts of the case. Assessing Officer is directed to determine ALP under the TNMM but restricting the amount of adjustment only to the International Transactions. (AY. 2012-13)
Mubea Automotive Components India (P) Ltd. v. Dy. CIT (2021) 214 TTJ 1047 / 63 CCH 501 / 208 DTR 217 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-CUP method is not the most appropriate method in the facts of the case-Assessing Officer is directed to determine ALP under the TNMM but restricting the amount of adjustment only to the International Transactions. [R. 10B]