TMI BlogTP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled...TP Adjustment - selection of MAM - CUP cannot be applied on basis of comparable uncontrolled transactions- internal or external- that are undertaken in different geographical markets as compared to the market in which the controlled transactions is undertaken.t is crystal clear that the assessee's transactions are with overseas FIIs and hence comparison with other overseas FIIs would alone be appropriate. The fact remains that domestic third party transactions are not comparable with the overseas FIIs on account of geographic differences. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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