Socomec Innovative Power Solutions (P) Ltd. v. Dy. CIT (2022) 219 TTJ 869 / 218 DTR 101 / 144 taxmann.com 169 (Chennai) (Trib)

S. 92C : Transfer pricing-Arm’s length price-CUP method-Matter remanded.

Held that TPO was not justified in summarily rejecting the CUP method adopted by the assessee for benchmarking the transactions of purchase of UPS with its AEs. TPO was directed to re-examine the case of the assessee and apply either CUP as considered by the assessee or RPM as proposed by the assesseee.  (AY. 2010-11, 2011-12)