“CUP method”

Transfer PricingSection 92CSection 92C828 judgments

The decision most relied on for CUP method is Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT (44 SOT 391), cited in 39 judgments on BharatTax.

Leading authorities on CUP method

Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT

44 SOT 391 · 2011 · ITAT

citing judgments

The Comparable Uncontrolled Price (CUP) method is preferred over indirect methods for determining the arm's length price in transfer pricing matters, especially for royalty payments.

Asstt. CIT v. MSS India (P.) Ltd.

32 SOT 132 · 2009 · ITAT

citing judgments

The Comparable Uncontrolled Price (CUP) method is preferred when comparable transactions with third parties are available to determine if transfer prices are at arm's length. Transactional profit methods are considered methods of last resort.

10 Glenmark Pharmaceuticals Ltd. v. Addl. CIT

43 Taxmann.com 191 · 2014 · Reported

citing judgments

Bank guarantee commission prices are not comparable to external CUPs for benchmarking corporate guarantees in transfer pricing.

CIT v. Eicher Motors Ltd.

293 ITR 464 · 2007 · High Court

citing judgments

Expenditure by way of royalty is an allowable revenue deduction if it is for a limited license to use know-how, where the assessee is not vested with proprietary rights. This is especially true if the payment falls within a reasonable range based on comparable transactions.

CIT v. Star Paper Mills Ltd.

172 Taxmann.com 391 · 2025 · High Court

citing judgments

The transfer price for intra-group services, specifically the sale of power from a captive power plant to a manufacturing unit, can be benchmarked based on the price at which the manufacturing unit procures power from the State Electricity Board, especially when it reflects a reasonable and arm's length price.

ACIT v. MSS India (P) Ltd.

123 TTJ 657 · 2009 · ITAT

citing judgments

A transfer pricing officer (TPO) must justify preferring one method over another, such as the Transactional Net Margin Method (TNMM) over the Comparable Uncontrolled Price (CUP) method, by demonstrating fallacies in the application of the preferred standard method.

Star India P. Ltd. v. ACIT

317 ITR 292 · 2009 · ITAT

citing judgments

When analyzing international transactions, separate classes of transactions, such as fees for technical know-how, use of trademarks, and procurement, must be analyzed individually, as each impacts profits. Aggregation of such transactions is not permissible.

Gharda Chemicals Ltd. v. Oy. CIT

39 SOT 93 · 2010 · ITAT

citing judgments

The Comparable Uncontrolled Price (CUP) method is the most preferred method for determining arm's length price in international transactions, but it requires a high degree of comparability. If comparables are not identical, the CUP method may not be applicable unless another method is proven to be more reliable in the specific fact situation.

Judgments citing CUP method

Axalta Coating Systems India Private Limted, Gurgaon vs. DCIT, Circle-3(2), New Delhi

In the result the grounds of appeal of the assessee in ITA

ITA 9344/DEL/2019[2015-16]Status: DisposedITAT Delhi14 Nov 2024AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Rajesh Kumar, CIT-DR

also confirmed the decision of the TPO. 5. On the issue of Interest on CCDs, the assessee benchmarked the transaction using CUP method as the most appropriate method. The assessee's coupon rate was 13 percent. The assessee obtained quotations comparable bank overdraft facility where rate was 15 percent

Parexel International Services India Pvt.Ltd, Chandigarh vs. ACIT, Circle-5(1), (Neac), Chandigarh

In the result, the appeal of the Assessee is partly allowed

ITA 129/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh28 Oct 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Reuben Mathew Jacob, Addl. CIT, Sr. DR

Section 143(3)Section 234BSection 271(1)(C)

such, that the TPO proposed the TP adjustment of Rs. 66,10,33,585/-. 8. The ld. DRP initially held the CUP method to be highly relevant for bench marking of intellectual property. However, the application of the CPM by the TPO was upheld as the most appropriate method ... cost plus mark up of 33.13% was imputed on the sale value of the intangibles. Thus, though the DRP principally held that the CUP method was the most relevant method for bench- marking the transfer of intangible assets, it upheld the CPM, as adopted by the TPO. However, the adjustment

ACIT-23(1), Mumbai, Piramal Chamber vs. Parishi Diamonds, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 1916/MUM/2024[2012]Status: DisposedITAT Mumbai22 Oct 2024

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

For Appellant: Mr. Rajesh SanghaviFor Respondent: 20/08/2024

Section 271GSection 92Section 92CSection 92D

using pricing study report, the transaction was benchmarked using pricing study report, the transaction was benchmarked using Parishi Diamonds 3 comparable un-controlled price (CUP) method as most appropriate controlled price (CUP) method as most appropriate controlled price (CUP) method as most appropriate method. The relevant conclusion mentioned ... available for comparison which are charged to independent party is available for comparison which are considered for determining arm's length test under CUP method In considered for determining arm's length test under CUP method In considered for determining arm's length test under CUP method In view

Vodafone India Ltd, Mumbai vs. DCIT 8(3)(2), Mumbai

Appeal are allowed for statistical purposes

ITA 6671/MUM/2017[2013-14]Status: DisposedITAT Mumbai22 Oct 2024AY 2013-14

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ketan VedFor Respondent: Date

Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 32Section 32(1)Section 35ASection 40

VSSL)] for grant of right to use "Vodafone" trademark and trade name. The Appellant contended that as per Comparable Uncontrolled Price Method (for short ‘CUP Method’) the royalty payment was at arm’s length since on analysis of the comparables selected, the Appellant found that the mean of the royalty ... more than what the Appellant had paid to its AE in the earlier ITA No.6671-Mum-2017 A.Y.2013-14 years. TPO noted that the Appellant had adopted CUP Method for benchmarking royalty transactions which according to the TPO was not the Most Appropriate Method. The TPO also rejected all the comparables selected

The ACIT, Circle-4(1)(1), Ahmedabad vs. M/S. Shell Energy India Pvt. Ltd. (Formerly Known As M/S. Hazira Lng. Pvt. Ltd.), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

ITA 558/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2012-13

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 Shell Energy India Pvt. Ltd. The Dcit, Cir.2(1)(1) Office No.2008, Westgage Vs Ahmedabad. Block-D, Makarba, Sg Highway Ahmedabad 380051. Pan : Aaach 9143 C Assessment Year : 2012-13 The Dcit, Cir.2(1)(1) Shell Energy India Pvt. Ltd. Ahmedabad. Vs (Formerly Known As M/S.Hqzira Lng P.Ltd.) Ahmedabad. Pan : Aaach 9143 C (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate, Shri Vishal Kalra & Ss Tomar, Ars. Revenue By : Shri (Dr.) Darsi Suman Ratnam, Cit-Dr Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/09/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/10/2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Guptathese Are Cross-Appeals By The Assessee & The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Ahmedabad Dated 23.09.2022 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act” For Short) For The Assessment Year 2012-13. Ita No.435 & 558/Ahd/2022

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri (Dr.) Darsi Suman Ratnam, CIT-DR

Section 143(3)Section 144CSection 250Section 92D

आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ ‘D’ अहमदाबाद

Shell Energy India Private Limited, Ahmedabad vs. The Deputy Commissioner of Income-Tax, Circle-2(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

ITA 435/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2012-13

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri (Dr.) Darsi Suman Ratnam, CIT-DR

Section 143(3)Section 144CSection 250Section 92D

Jcb India Limited, New Delhi vs. DCIT, Circle - 13(1), New Delhi

In the result appeal for assessment year 2009-10, 2013-14 in respect of transaction with non-AE is set aside to Id

ITA 512/DEL/2022[2017-18]Status: FixedITAT Delhi15 Oct 2024AY 2017-18

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 143(3)Section 144BSection 144C

without appreciating or erring: 5.1. the economic analysis, benchmarking methodology followed, and arbitrarily rejecting/ ignoring the uncontrolled comparable license agreements identified for applying CUP method in its transfer pricing documentation maintained as per the provisions of the Art 5.2 the corroborative benchmarking of royalty payment under Transaction Net Margin Method

Bosch Rexroth (India) Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 448/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R

Section 145ASection 40

issue relating to this Ground of Appeal is with regards to the TPO's choice of the Comparable Uncontrolled Price (CUP) method for evaluating international transactions relating to these payments made by the Assessee. The Assessee challenged the TPO's adoption of the CUP method on the ground that ... inappropriate due to the TPO's failure to identify any actual comparable uncontrolled price. The Assessee submitted that the CUP method relies on the comparability of products and contractual terms, and significant differences in geographic markets could undermine the reliability of any price comparison. The assessee submitted that even

Hagglunds Drives (India) Pvt. Ltd. ( Now Merged in Bosch Rexroth (India) Ltd.), Ahmedabad vs. The Dy.CIT, Circle-1(1)(2), Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 931/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2010-11

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R

Section 145ASection 40

ACIT, Circle-1(1)(1), Ahmedabad, Vejalpur vs. Adani Enterprises Limited, Ahmedabad

In the result, appeal of the Revenue is dismissed due to low tax effect

ITA 264/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Oct 2024AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.264/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 The Acit Adani Enterprises Ltd. बनाम/ Circle-1 (1)(1) Adani Corporate House V/S. Ahmedabad Shantigram Near Vaishno Devi Circle S.G. Highway Khodiyar Ahmedabad- 382 421 (Gujarat) "थायी लेखा सं./Pan: Aabca 2804 L अपीलाथ&/ (Appellant) '( यथ&/ (Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Surendra Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/10/2024 घोषणा की तारीख /Date Of Pronouncement: 03/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Surendra Kumar, Sr.DR

Section 143(3)Section 144BSection 144C(3)Section 250Section 37Section 92(3)

lower than the market value for the benchmarking under CUP without appreciating the fact that aggregation of the transactions is not allowed in the CUP method which is contrary to the provisions of the Rule 10B of Income Tax Rules? 4. Whether on the facts and in the circumstances ... case and in law, the Ld. CIT(A) erred in holding that aggregation of the transactions is considered in CUP method without appreciating the fact that each transactions is treated and benchmarked separately? The ACIT vs. Adani Enterprises Ltd. Asst. Year : 2018-19 3 5. Whether on the facts

Tata Consumer Products Limited, Kolkata vs. DCIT, Cir.-4(1), Kolkata

In the result, the appeal for AY 2014-15 is partly allowed

ITA 373/KOL/2021[2015-16]Status: DisposedITAT Kolkata17 Sept 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR

Section 250Section 43(6)Section 50CSection 50C(2)Section 928

decision of M/s Everest Kanto Cylinder Lad wherein it was held that guarantee is an international transaction. [Page 870 of PB] b. CUP method is the most appropriate method to benchmark the transaction. [Page 866 of PB]. As regards the determination of the guarantee fee, it was held that

Tata Consumer Products Limited, Kolkata vs. DCIT, Cir.-4(1), Kolkata

In the result, the appeal for AY 2014-15 is partly allowed

ITA 372/KOL/2021[2014-15]Status: DisposedITAT Kolkata17 Sept 2024AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraassessment Years: 2014-15 & Assessment Years: 2015-16

For Appellant: Sriram Sashdari, ARFor Respondent: Rakesh Kumar Das, CIT, DR

Section 250Section 43(6)Section 50CSection 50C(2)Section 928

The ACIT, Anand Circle, Anand vs. M/S. Chhotabhai Jethabhai Patel & Co., Kheda

In the result, the appeal of the revenue is dismissed

ITA 201/AHD/2021[2014-15]Status: DisposedITAT Ahmedabad12 Sept 2024AY 2014-15

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

For Appellant: Shri Bandish Soparkar, A.RFor Respondent: Shri Ashesh R. Rewar, Sr. D.R

Section 143(2)Section 143(3)Section 144Section 50CSection 80ISection 92C

erred in allowing the assessee to take yearly average price of the transactions for comparing the same to comparable transaction in CUP method without appreciating the fact that each transaction is treated and benchmarked separately while applying CUP method? 3. Whether on the facts and in the circumstances ... erred in allowing the assessee to take yearly average price of the transactions for comparing the same to comparable transaction in CUP method which is contrary to the provisions of the Rule 10B of Income Tax Rules? 4. Whether on the facts and in the circumstances of the case

Asiatic Colour Chem Industries Private Ltd., Ahmedabad vs. The Jt.. Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 60/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad11 Sept 2024AY 2015-16

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

For Appellant: Shri Chetan Agrawal, A.RFor Respondent: Shri Ashesh R. Rewar, Sr. D.R

Section 143(3)Section 40Section 92C

CUP Ltd. work - The Assessing Officer further observed that the assessee company purchased chemical products from its AEs and bench mark the same using CUP method. The Assessing Officer observed that certain transactions were price beyond the arm length price. After taking cognizance of the assessee’s reply/submissions, the Assessing

Comparex India P.Ltd, New Delhi vs. ITO, Circle-4(2), New Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 2151/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Sept 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Accountant Member)

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Rajesh Kumar, CIT DR

Section 143(2)Section 143(3)Section 144C(10)Section 144C(13)Section 144C(8)Section 92CSection 92C(3)

fees 4. On the facts and in law, the Revenue erred in rejecting the economic analysis and arbitrarily selecting Comparable Uncontrolled Price ('CUP') method. In doing so, the Revenue failed to discharge the statutory onus to establish if any of the conditions specified in clause (a) to (d) of Section ... facts and in law, Revenue erred in determining the ALP for shared services charges, holding fees and ERP fees at NIL by applying the CUP method without bringing on record any comparable uncontrolled transaction. Therefore, the revenue has violated section 92C of the Act 4 read with Rule

M/S Emerson Automation Solutions Intelligent Platforms Pvt. Ltd, Bangalore vs. DCIT, C-3(1)(2), Bangalore

In the result, the Ground Nos

ITA 9/BANG/2019[2014-15]Status: DisposedITAT Bangalore30 Aug 2024AY 2014-15

Bench: Shri Prakash Chand Yadav & Shri Waseem Ahmedm/S Emersion Automation Solutios The Deputy Commissioner Intelligent Platforms Private Limited Of Income Tax, Circle- (Formerly M/S Ge Intelligent 3(1)(2), Bmtc Building, Platforms Private Limited), Velankani Vs. Koramangala, Bangalore Tech Park, Building 9, First Floor, 43 Hosur Road, Bangalore-560100 Pan – Aaacg7573K (Appellant) (Respondent) Assessee By: Sri. Sachit Jolly & Sri. Rishabh Malhotra, Advocates Revenue By: Sri. Subramanian. S, Jcit Date Of Hearing: 13.08.2024 Date Of Pronouncement: 30.08.2024 O R D E R Per: Prakash Chand Yadav,J.M. Present Appeal Of The Assessee Is Arising From The Order Of Ld. Ao / Drp Dated 30Th October, 2018. The Assessee Has Raised 19 Grounds Of Appeal Out Of Which Ground Nos. 1 To 5 Are General In Nature & Hence Not Required Specific Adjudication. Ground No. 6 Related To The Grievance Of The Assessee With Respect To The Adjustment Of Custom Duty, Base Cost, Working Capital Not Granted By The Ao While Completing The Assessment. Ground No. 7 Is With Respect To The Applicability Of Tnmm Method Instead Of Rpm Method Applied By The Assessee For Its Trading Segment Transactions. Ground Nos. 8, 9 & 10 Are Related To The Rejection Of Comparability Analysis Conducted By The Tpo As Affirmed By The Drp & Followed By Ao. Ground No. 11 Is With Respect To The Adjustment Of Working Capital Denied By Tpo Affirmed By Drp & Followed By Ao. Ground No. 12 Is With Respect To The Disallowance Of Foreign Exchange Fluctuation & Ground Nos. 13 & 14 Is With Respect To The Payments Made To Headquarters In Lieu Of Services Obtained By Applying

For Appellant: Sri. Sachit Jolly & Sri. RishabhFor Respondent: Sri. Subramanian. S, JCIT

Section 115JSection 142(1)Section 143Section 143(1)Section 143(2)Section 143(3)Section 144Section 144CSection 271(1)(b)Section 5

assessee has opted TNMM method. The method adopted by the assessee has been rejected by the TPO and the ld. TPO applied the CUP method. 31. The ld. DR argued that the assessee has failed to establish that it has received any services from its AE. The next averment

Borgwarner Emissions Systems India Private Limited, New Delhi vs. DCIT, Circle-4(2), Delhi

Appeal is allowed

ITA 2015/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Aug 2024AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Narinder Kumar

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri Rajesh Kumar, CIT(DR)

Section 143(3)Section 234BSection 271(1)(c)Section 92C

been held by the Co-ordinate Benches of the Appellate Tribunal that in absence of any comparable uncontrolled instances, CUP method is not to be applied, and that only TNM method would be applicable. In the course of arguments, we raised a specific query to Learned ... ACIT, (2014) 52 taxmann.com 240 (Delhi). 36. In reply, learned AR for the assessee has submitted that in the first round, CUP method was adopted by the TPO, but in the second round, TNM method has been adopted, and that no justification has been given for adopting TNMM

Gates India Pvt Ltd, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 2379/DEL/2022[2018-19]Status: DisposedITAT Delhi22 Aug 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri Pradip Kumar Kedia

For Appellant: Shri M.P. Rastogi, AdvFor Respondent: Shri Rajesh Kumar, CIT-(DR)

Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 92CSection 92C(1)

payments made and no independent enterprise would make such payments without making the cost benefit analysis. The TPO/AO also rejected TNMM method and applied CUP method as most appropriate method to determine ALP of such management service and assigned a ‘Nil’ value towards cost of such management services ... Sony Ericson (supra), the TNMM method adopted by the assessee on aggregate basis was justified and ought not to have been replaced by CUP method. (ii) The action of TPO / AO to treat management services as separate international transaction without bifurcation/ segregation would lead to unusual and incongruous results

ADIT, Cirlce- 1(1), International Taxation, New Delhi vs. American Express Banking Corp. (India Branch), New Delhi

In the result, the Appeal filed by the Assessee in ITA No

ITA 6455/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Aug 2024AY 2009-10

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 92C(3)Section 92F

Learned AO/ Learned TPO have erred in law by upholding the determination of the ALP of the international transaction using Comparable Uncontrolled Price (CUP) method without following the manner of applying the CUP method prescribed under Rule 108(1)(a) of the Rules 8. The Learned CIT(A)/ Learned ... Learned TPO have erred by upholding the adoption of CUP method as the most appropriate method for determining the arm's length price in respect of the intra group services without identifying any comparable uncontrolled transaction(s) for the computation of the ALP as prescribed in Section

American Express Banking Corp. (India Branch), New Delhi vs. ADIT, Cirlce- 1(1), International Taxation, New Delhi

In the result, the Appeal filed by the Assessee in ITA No

ITA 6253/DEL/2017[2009-10]Status: DisposedITAT Delhi07 Aug 2024AY 2009-10

Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 92C(3)Section 92F