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2019 (5) TMI 1371 - AT - Income TaxTP adjustment - selection of MAM - CUP OR TNMM - CIT(A) stated that CUP should not be the most appropriate method for sale of finished goods - HELD THAT:- As decided in assessee's own case [ 2018 (6) TMI 962 - ITAT KOLKATA] whereby the issue of CUP method Vs. TNMM has been discussed and upheld that TNMM is most appropriate method (MAM). Selective application of CUP Method by TPO is ad hoc, and without any cogent basis, hence the entire approach followed in rejecting the TP study memorandum of assessee for application of TNMM method is unjustified - Decided in favour of the assessee Corporate guarantee fee extended by the assessee company to its Associate Enterprise (AE) - international transaction - HELD THAT:- . We rely on the judgment of the Co-ordinate Bench of ITAT, Delhi in the case of Bharti Airtel Ltd. vs. ACIT [2017 (1) TMI 172 - ITAT DELHI] wherein the definition of international transaction in view of the amendments, vide Finance Act, 2012, had been discussed and it was held that the provision of corporate guarantee is not an international transaction. - Decided in favour of the assessee
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