Transfer Pricing Adjustments - benchmarking the purchase of SIM ...

Income Tax

June 19, 2023

Transfer Pricing Adjustments - benchmarking the purchase of SIM cards by the assessee from its AEs - selection of MAM - CUP v/s RPM - CIT(A) has incorrectly applied the CUP method based on incomplete data, ignoring geographical differences and contrary to the Assessee’s own TP Analysis and contrary to TP Auditor’s Report. CIT(A) has also erroneously aggregated the transactions despite judicial pronouncements on the issue. - AT

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Transfer Pricing Adjustments - benchmarking the purchase of SIM ...

Income Tax

June 19, 2023

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