Monday 21 December 2015

Neither AO nor TPO can resort to cherry-picking of uncontrolled transactions under CUP method

IT/ILT: While determining ALP under CUP method, if number of comparable uncontrolled transactions are available, it is arithmetic mean of price charged in all such transactions, which is considered for determining ALP of an international transaction; in such a case, neither Assessing Officer nor Transfer Pricing Officer can resort to cherry-picking

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