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2010 (7) TMI 520 - ITAT BANGALOREArm's Length Price - Scrutiny - CUP or TNMM method - The assessee itself admits that there are no transactions after July, 2003 and that the assessee continues to incur freight & clearing charges - As per News Article dated January 23, 2003 in The Financial Express and Press Articles on crop failure during the years 2002 and 2003, again available in the public domain, the monsoon failure in 2002 coupled with 33% deficiency in post-monsoon rains over the country led to crop failure - the operating gross profit margin earned from the Global Trading Division was better than last year and price charged for Niger Seeds was also better - It is also evident that prices charged to 3M US were higher than market price or ALP - Therefore, it cannot be held that price charged was not at arm's length. - Decided in the favour of the assessee
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