IT/ILT : CPM is not a residuary method in the sense that if every other method of ascertaining the arm's length price fails, CPM can be applied on the basis of imperfect data. If at all there is a residuary method, or what is termed as the method of last resort, it is transactional net margin method. TNMM has almost become the 'default' method for taxpayers in recent years
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