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“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
39
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
26
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
26
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
22
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
21
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
16
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
16
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
16
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

Te Connectivity India Private Limited, Bangalore vs. The Office of the Deputy Commissioner of Income-Tax, Circle 7(1)(1), Bangalore

In the result, the appeal of the assessee is hereby partly allowed

ITA 1789/BANG/2024[2020-21]Status: DisposedITAT Bangalore08 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Darpan Kriplani, CAFor Respondent: Dr. KJ Dhivya, CIT (DR)

most appropriate method except for certain transactions such reimbursement of ESOP, recovery of expenses and interest expenses were benchmark using other methods and CUP method respectively. The assessee computed PLI for said 3 segments as OP/OC. In computation of PLI, the assessee treated remeasurement gain on defined employee benefit plan ... Concur expenses (18,18,346/-) and Corporate service charges of Rs. 6,7001298/- was determined at NIL under the CUP method, resulting in a upward TP adjustment. 41. The aggrieved assessee preferred to file objection before the before the learned DRP. 42. The assessee, in the course of proceedings before

DCIT, New Delhi vs. M/S. Exxon Mobil Lubricants Pvt. Ltd., New Delhi

ITA 1348/DEL/2012[2005-06]Status: DisposedITAT Delhi07 Jan 2026AY 2005-06

Bench: Ms. Madhumita Roy & Shri Manish Agarwal

Section 143(2)Section 143(3)Section 250(6)Section 40Section 92C

with AE, the Ld. CIT-DR submits that with respect to the benchmarking under manufacturing segment of import of base oils, assessee had taken CUP method as most appropriate method (MAM), however TPO given very specific reasons for not accepting the CUP method. As per ld. CIT DR, TPO observed ... comparable prices for 31 transactions and with respect to remaining transactions precise dates and value of import do not match so as justifying the CUP method. The Ld. CIT-DR submits that the Ld. CIT(A) has failed to consider this aspect and further failed to give any reasons

Marks and Spencer (India) Private Limited, Gurgaon vs. ACIT, Circle 1(1), Gurgaon

In the result, appeal filed by the assessee is allowed for statistical purpose

ITA 1937/DEL/2022[2018-19]Status: DisposedITAT Delhi05 Jan 2026AY 2018-19

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

For Appellant: Shri Ravi Sharma, AdvocateFor Respondent: Shri Dharm Veer Singh, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 92C

TNMM as most appropriate method opted by the assessee, disregarded economic analysis carried out by the assessee and applied an arbitrary Comparable Uncontrolled Price (‘CUP’)method;  rejected the corroborative CUP analysis submitted by the assessee without providing any cogent reason. 9. Based on the above, the TPO arrived ... Additionally, Profit Level Indicator (‘PLI’) used in TNMM are less affected by transactional differences than in the case with price as used in the CUP method. Differences in the functions performed between enterprises are often reflected in variations in operating expenses. Consequently, enterprises may have a wide range of gross

DCIT, New Delhi vs. M/S. Cargil India Pvt. Ltd., New Delhi

In the result the appeal of the Revenue is dismissed

ITA 5786/DEL/2014[2005-06]Status: DisposedITAT Delhi30 Dec 2025AY 2005-06

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2005-06 Acit, Circle5(2), Vs. M/S Cargil India Pvt.Ltd. New Delhi -110001 111 Rectangle–I Saket District Centre New Delhi Pan No. Aaacc3269J (Appellant) (Respondent)

Section 143(1)Section 143(2)Section 143(3)Section 36(1)(iii)

York Board of Trade (“NYBOT”) quotes as a valid external comparable uncontrolled price (“CUP”) for the purpose of benchmarking the subject transaction under CUP method. NYBOT quotes were inherently Free on Board (“FOB”) in nature. NYBOT prices on any given date are available only for four delivery months ... same result. The TPO has further observed that as far as possible, for the purposes of establishing the comparability for the application of the CUP method, the FOB prices should be used. In the present case the CIF price was converted into FOB prices by the TPO. For the purposes

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2767/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

2367/Mum/2025 I.T.A. No. 2767/Mum/2025 C.O. No. 112/Mum/2025 C.O. No. 111/Mum/2025 C.O. No. 113/Mum/2025 C.O. No. 114/Mum/2025 C.O. No. 115/Mum/2025 9 External Comparable Uncontrolled Price (CUP) method. No internal CUP was available with the assessee as AE was treated as the tested party. The method of determining ... 115/Mum/2025 2.9.3 Without prejudice to the above submissions, the assessee benchmarked the loan transaction on the basis of External Comparable Uncontrolled Price [CUP] Method by comparing the interest rates at which the independent parties with similar credit ratings would be able to obtain intra-group intra loans

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2367/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

point and thus, the total interest was determined at Rs.6,27,50,560/-, details of which were submitted as under:- External Comparable Uncontrolled Price (CUP) method. No internal CUP was available with the assessee as AE was treated as the tested party. The method of determining ... outside South Africa. 2.9.3 Without prejudice to the above submissions, the assessee benchmarked the loan transaction on the basis of External Comparable Uncontrolled Price [CUP] Method by comparing the interest rates at which the independent parties with similar credit ratings would be able to obtain intra-group intra loans

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment

ITA 2366/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Dec 2025AY 2015-16

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

115/Mum/2025 4. 7. The Ld.TPO noted that assessee benchmarked the international transactions of interest payment on the basis of External Comparable Uncontrolled Price (CUP) method. No internal CUP was available with the assessee as AE was treated as the tested party. The method of determining the ALP of the transactions ... 115/Mum/2025 2.9.3 Without prejudice to the above submissions, the assessee benchmarked the loan transaction on the basis of External Comparable Uncontrolled Price [CUP] Method by comparing the interest rates at which the independent parties with similar credit ratings would be able to obtain intra-group intra loans

DCIT(CC)-8(3), Mumbai vs. Jsw Energy Limited, Mumbai

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

ITA 2365/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Dec 2025AY 2014-15

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)

2367/Mum/2025 I.T.A. No. 2767/Mum/2025 C.O. No. 112/Mum/2025 C.O. No. 111/Mum/2025 C.O. No. 113/Mum/2025 C.O. No. 114/Mum/2025 C.O. No. 115/Mum/2025 External Comparable Uncontrolled Price (CUP) method. No internal CUP was available with the assessee as AE was treated as the tested party. The method of determining the ALP of the transactions ... 115/Mum/2025 2.9.3 Without prejudice to the above submissions, the assessee benchmarked the loan transaction on the basis of External Comparable Uncontrolled Price [CUP] Method by comparing the interest rates at which the independent parties with similar credit ratings would be able to obtain intra-group intra loans

Satia Industries Limited, Muktsar vs. DCIT/ACIT Circle I, Bathinda

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

ITA 702/ASR/2024[2021-22]Status: DisposedITAT Amritsar16 Dec 2025AY 2021-22

Bench: Dr. M. L. Meena & Sh. Udayan Dasgupta

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 143(3)Section 144C(1)Section 144C(2)Section 144C(5)Section 80Section 80GSection 80ISection 92C

raised a SCN proposing an adjustment of Rs. 19,44,90,568/- in ALP of power and steam, by application of external CUP method for electricity and cost-plus method for steam, due to the reasons that no power generator is permitted by the “State Electricity Regulatory authority” to supply ... from the Transactional Net Margin Method (TNMM) to the Cost Plus Method in the case of steam, and to the External Comparable Uncontrolled Price (CUP) method in the case of electricity, without considering the fact that the TNMM method adopted by the appellant was the most appropriate method to determine

Shri Sureshkumar Harjivanbhai Chandarana, Rajkot vs. The ACIT, Circle - 2 (2) (1), Rajkot

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

ITA 415/RJT/2023[2016-17]Status: HeardITAT Rajkot15 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 415/Rjt/2023 (िनधा"रण वष"/Assessment Year: (2016-17) Sureshkumar Harjivanbhai Chandarana Acit, Circle – 2(2)(1), Rajkot A-75, New Market Yard, Village-Bedi, Vs. Aayakar Bhavan, Race Course Ring Morbi, Highway, Rajkot- 360 003 Road, Rajkot –360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpc8536E (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Durga Dutt, Ld. Cit(Dr) Date Of Hearing : 27/11/2025 : 15/12/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By Commissioner Of Income-Tax, Appeal Cit(A), Ahmedabad-13 Dated 06.10.2023 [In Short, “Ld. Cit(A)”], Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(3) Of The Act, Vide Order Dated 19.12.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Durga Dutt, Ld. CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

appeal before this Tribunal. 9. Shri Mehul Ranpura, the Learned Counsel for the assessee, argued, on merit, that the assessee has adopted CUP method (comparable uncontrolled price method) for its specified domestic transactions. However, during the assessment proceedings, the assessing officer has adopted TAMM (Transactional Net Margin Method ... Counsel for the assessee submitted that the appropriate method, as per the nature of transaction in the assessee`s case is the CUP method. The assessee has been adopting CUP method (comparable uncontrolled price method), for bench marking the specified domestic transaction, and for that the assessee has submitted necessary

Compunnel Technology India (P) Ltd, Noida vs. ACIT Circle-4(2), New Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 550/DEL/2021[2016-17]Status: DisposedITAT Delhi15 Dec 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla[Assessment Year:2016-17] Compunnel Technology India Assistant Commissioner Of Income Private Limited, Tax, Circle-4(2), C-4, Sector-58, Noida, Vs New Delhi Uttar Pradesh-201301 Pan Aaaci5095A Appellant Respondent Assessee By Shri Dinesh Gupta, Ar Revenue By Shri Dharm Veer Singh, Cit(Dr) Date Of Hearing 15.12.2025 Date Of Pronouncement 15.12.2025

Section 144Section 92CSection 92D

been satisfied. 3. On facts and in law, the Ld. AO/Ld. TPO/ Ld. DRP erred in rejecting the Comparable Uncontrolled Price ("CUP) Method and inappropriately applying the Transactional Net Margin Method ("TNMM") as the most appropriate method. 4. On facts and in law, the Ld. AO/the ... erred in ignoring the 'Rule of Consistency in case of the Assessee as CUP method was accepted as the most appropriate method in AY 2011-12 and AY 2012-13 by the erstwhile Ld. TPOs. 5. Without prejudice, on facts

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

facts and circumstances of the case, in rejecting, without any cogent reason, the assessee’s most appropriate method being ‘CUP Method’ which is a direct price based method and instead applying the ‘TNMM’ in an arbitrary manner, not providing FAR analysis and search process to assessee and resultantly taking companies ... qualify as an appropriate comparable data under CUP method instead it is the actual price charged by the State Electricity Board (which actually sells electricity to consumers) which can be used as appropriate comparable in the application of CUP method. 10.4 That the Ld. DRP / Ld. TPO / Ld. AO have

Tata Steel Limited (Successor of Angul Energy Limited), Delhi vs. Assistant Commissioner of Income-Tax, New Delhi

In the result, assessee’s appeal in ITA No

ITA 4171/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2020-21

Section 143(3)Section 144C(13)Section 144C(5)Section 153(3)Section 270ASection 80Section 92BSection 92CSection 93C

more than the interest paid by TSBSL on the term loan facility @ 9%. Ultimately, vide order dated 28.07.2023 the Learned TPO though accepted the CUP method adopted by the Assessee to benchmark the rate of interest, however, made adjustment of Rs. 12,19,11,871/- on account of lower interest

Srf Limited, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

facts and circumstances of the case, in rejecting, without any cogent reason, the assessee’s most appropriate method being ‘CUP Method’ which is a direct price based method and instead applying the ‘TNMM’ in an arbitrary manner, not providing FAR analysis and search process to assessee and resultantly taking companies ... qualify as an appropriate comparable data under CUP method instead it is the actual price charged by the State Electricity Board (which actually sells electricity to consumers) which can be used as appropriate comparable in the application of CUP method. 10.4 That the Ld. DRP / Ld. TPO / Ld. AO have

Srf Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

facts and circumstances of the case, in rejecting, without any cogent reason, the assessee’s most appropriate method being ‘CUP Method’ which is a direct price based method and instead applying the ‘TNMM’ in an arbitrary manner, not providing FAR analysis and search process to assessee and resultantly taking companies ... qualify as an appropriate comparable data under CUP method instead it is the actual price charged by the State Electricity Board (which actually sells electricity to consumers) which can be used as appropriate comparable in the application of CUP method. 10.4 That the Ld. DRP / Ld. TPO / Ld. AO have

M/S. Tega Industries Limited, Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

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

ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)

case (ITA NO. 1047,1048 & 1049/Kol/2017). 2.2.4. Applying an arbitrary approach to benchmark the corporate guarantee transaction by erroneously using Comparable Uncontrolled Price ("CUP") method as the most appropriate transfer pricing method, although the said method applied is not in accordance with the first proviso to section ... have grossly erred by amongst other things: 2.3.1. Applying an arbitrary approach to benchmark the corporate guarantee transaction by erroneously using Comparable Uncontrolled Price ("CUP") method as the most appropriate transfer pricing method, although the said method applied is not in accordance with the first proviso to section

Vodafone West Limited, (Formerly Known As Vodafone Essar Gujarat Limited), Ahmedabad vs. The Dy.CIT, Circle-4(1)(2), Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical

ITA 671/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48Section 50D

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

The Dy CIT, Circle-4(1)(2), Ahmedabad vs. Vodafone West Limited, Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical

ITA 1634/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48Section 50D

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL

Pico Deepali Overlays Consortium (by Deepali Designs Exhibits (P.) Ltd.), Delhi vs. DCIT, Central Circle-17, New Delhi

In the result, both the captioned appeals filed by the assessee are allowed

ITA 518/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

issue were left open. Reference to order in Miscellaneous Application dated 11.01.2021 is important. Ld. DRP had TNMM Method. Ld. AO took CUP method and held nil as Intra-Group Services. Undisputedly, services were provided by PICO Hong Kong. Despite order being set aside, Ld.TPO maintained the same. Reference ... Event Management 2080 is important. Ld. TPO wrongly held no disallowances were filed, in fact, details were filed, Ld. TPO used CUP Method without comparable data. In direct expenses which is at page no. 399 of paper books and balance sheet at page no. 404. Therefore

Pico Deepali Overlays Consortium, Haryana vs. DCIT Central Circle 17, Delhi

In the result, both the captioned appeals filed by the assessee are allowed

ITA 412/DEL/2022[2011-12]Status: DisposedITAT Delhi10 Dec 2025AY 2011-12

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2011-12 Pico Deepali Overlays Vs. Dcit, Central Circle-17, Consortium, C/O Mna & Co., Delhi Cas, Suite 444, Tower-B, Spazedge, Sector 47, Sohna Road, Gurgaon – 122 018 Pan :Aabap1880F (Appellant) (Respondent)

Section 144CSection 153ASection 92C

issue were left open. Reference to order in Miscellaneous Application dated 11.01.2021 is important. Ld. DRP had TNMM Method. Ld. AO took CUP method and held nil as Intra-Group Services. Undisputedly, services were provided by PICO Hong Kong. Despite order being set aside, Ld.TPO maintained the same. Reference ... Event Management 2080 is important. Ld. TPO wrongly held no disallowances were filed, in fact, details were filed, Ld. TPO used CUP Method without comparable data. In direct expenses which is at page no. 399 of paper books and balance sheet at page no. 404. Therefore