Tuesday, 1 September 2015

CUP method couldn't be adopted without FAR analysis if TNMM was adopted in earlier year

IT/ILT : Where Tribunal in earlier year adopted TNMM in assessee's case for determining ALP, in absence of change in circumstances, TPO could not make addition to assessee's ALP by adopting CUP method during relevant year without conducting any FAR analysis

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