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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

Andhra Paper Limited, Rajahmundry vs. Assistant Commissioner of Income Tax, Circle-1, Rajahmundry

In the result, appeal of the assessee is dismissed

ITA 349/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam05 Dec 2025AY 2020-21

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.349/Viz/2024 (निर्धारण वर्ा/ Assessment Year:2020-21) Vs. Acit – Circle -1 Andhra Paper Limited 14-6-9, Admin Office Veerabhadrapuram Kateru Road Rajahmundry-533101 Sri Ramnagar S.O. (Rajahmundry) Andhra Pradesh Rajahmundry (Urban) East Godavari – 533105 Andhra Pradesh [Pan: Aaact8849D]

Section 142(1)Section 143(2)Section 143(3)Section 92C

respect of the International Transactions reported by the assessee during the A.Y.2020-21. As per Form 3CEB the following International Transactions have been benchmarked using CUP Method. Page. No 2 I.T.A.No.349/VIZ/2024 Andhra Paper Limited 35th to 65th Amount Method Description Rate (In response) adopted Percentile Royalty ... bearing the trademark of HP Group and Hammermill @0.5% and 1% respectively. Assessee benchmarked these royalty payments and the ALP was determined by applying CUP Method considering it to be the Most appropriate Method (MAM). 6. The assessee in its TP study conducted search in the different databases, namely ktMINe

DCIT, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

erred in law and on the facts and in circumstances of the case in upholding the application of Comparable Uncontrolled Price ("CUP") method as the most appropriate method to determine the arm's length nature of payment of royalty for use of technology disregarding the application of Transactional Net Margin ... payment transaction with other transactions. Regarding the contention that TNMM is the most appropriate method for benchmarking the transaction, the TPO observed that either CUP method or 'Other Method' can be considered to be the most appropriate method. 3.4.5 The TPO observed that same technology is being received and applied

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR
Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

erred in law and on the facts and in circumstances of the case in upholding the application of Comparable Uncontrolled Price ("CUP") method as the most appropriate method to determine the arm's length nature of payment of royalty for use of technology disregarding the application of Transactional Net Margin ... payment transaction with other transactions. Regarding the contention that TNMM is the most appropriate method for benchmarking _ the transaction, the TPO observed that either CUP method or ‘Other Method' can be considered to be the most appropriate method. 3.4.5 The TPO observed that same technology is being received and applied

Brightcom Group Limited (Formerly Known As Lycos Internet Limited), Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14
Section 145Section 92BSection 92C

following a policy of not charging interest on receivables irrespective of whether the sales are made to AE or Non-AE. Hence, considering the CUP method as well, the transactions with AE are at arm's length. 1.8. Without prejudice to the above grounds, ought to have appreciated the fact

Balaji Powertronics, New Delhi vs. DCIT, Circle- 43(1), New Delhi

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

ITA 2743/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Dec 2025AY 2017-18

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2017-18 M/S. Balaji Powertronics, Vs. Dcit, Circle-43(1), H-56, Udyog Nagar, New Delhi Main Rohtak Road, Delhi – 1100 41 Pan :Aagfb0501M (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 270ASection 80Section 928A

present case, even considering the fact the TPO has held that the TNMM method is the most appropriate method and not the CUP method, following adjustment are necessary to make the comparative figures of OP/OR with the comparable: 8 (a) Adjustment for excise duty; & (b) Adjustment

Matrix Clothing Private Limited, Gurgaon vs. ACIT-CC-18, Delhi

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

ITA 3805/DEL/2024[2020-21]Status: DisposedITAT Delhi01 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR
Section 133(6)Section 143(3)Section 144C(5)Section 92C

presumption that assessee has basically charged nothing from its AE on account of SBLC charges and accordingly proceeded to adopt ‘Comparable Uncontrolled Price’ (CUP) method as the most appropriate method to benchmark this transaction. For this purpose, the ld TPO collected data from various banks ... account of SBLC on cost to cost basis from its AE. Hence, the entire benchmarking analysis carried out by the ld TPO using external CUP method is totally flawed as it is based on incorrect assumption of facts. In any case, the bank guarantee commission charges cannot be equated with

Matrix Clothing Private Limited, Gurgaon vs. ACIT, Central Circle-18, Delhi

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

ITA 760/DEL/2022[2017-18]Status: DisposedITAT Delhi01 Dec 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumarmatrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B Assessee By : Ms. Kavita Jha, Sr. Adv Shri Himanshu Agarwal, Adv Shri Akash Shukla, Adv Revenue By: Shri Chetan P. S. Rao, Cit Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 01/12/2025 Matrix Clothing Pvt. Ltd, Vs. Acit, Village Mohammadpur, Central Circle-18, Khandsa Road, Gurgaon- Delhi 122 001, Haryana (Appellant) (Respondent) Pan: Aabcm8475B

For Appellant: Ms. Kavita Jha, Sr. AdvFor Respondent: Shri Chetan P. S. Rao, CIT DR
Section 133(6)Section 143(3)Section 144C(5)Section 92C

presumption that assessee has basically charged nothing from its AE on account of SBLC charges and accordingly proceeded to adopt ‘Comparable Uncontrolled Price’ (CUP) method as the most appropriate method to benchmark this transaction. For this purpose, the ld TPO collected data from various banks ... account of SBLC on cost to cost basis from its AE. Hence, the entire benchmarking analysis carried out by the ld TPO using external CUP method is totally flawed as it is based on incorrect assumption of facts. In any case, the bank guarantee commission charges cannot be equated with

Hi-Lex India Private Limited, Gurgaon vs. Assessment Unit Income Tax Department, Gurgaon

In the result, Appeal of the Assessee is allowed

ITA 4288/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Nov 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Brajesh Kumar Singh

Section 144(3)Section 144BSection 144C(13)

average royalty rate of 6.17% of net sales as against 3% of net sales royalty paid in its case. The Ld. TPO applying the CUP Method, used final set of 5 agreements as comparable with average royalty rate of 2.6% and proposed addition as under:- Particulars Amount (INR) Royalty paid ... most appropriate method for the payment of technical assistance fee of Rs. 38,58,80,000 only for which Comparable Uncontrolled Price ("CUP") method was sought to be applied. Here, this court concurs with the assessee that having accepted the TNMM as the most appropriate, it was not open

Assisstant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4935/MUM/2024[2017]Status: DisposedITAT Mumbai24 Nov 2025

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

Section 133(6)Section 80I

assessee which was used capitvely to meet its energy requirements. 4.1. The Ld. AR submitted that, the transaction was benchmarked by the assessee selecting CUP method as the most appropriate method and the rate was compared with the rate per unit of electricity purchased by the assessee from India Energy

Assistant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4933/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Nov 2025AY 2018-19

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

Section 133(6)Section 80I

assessee which was used capitvely to meet its energy requirements. 4.1. The Ld. AR submitted that, the transaction was benchmarked by the assessee selecting CUP method as the most appropriate method and the rate was compared with the rate per unit of electricity purchased by the assessee from India Energy

Assistant Commissioner of Income Tax, Mumbai vs. Asr Multimetals Private Limited, Mumbai

In the result, appeals for all the assessment years filed by the revenue stand dismissed

ITA 4931/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

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

Section 133(6)Section 80I

assessee which was used capitvely to meet its energy requirements. 4.1. The Ld. AR submitted that, the transaction was benchmarked by the assessee selecting CUP method as the most appropriate method and the rate was compared with the rate per unit of electricity purchased by the assessee from India Energy

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

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

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

length price has to be done by using the most appropriate method. The most appropriate method must be selected from the following methods: • CUP Method; • RPM; • CPM; • PSM; • TNMM; or 26 OECD Guidelines. Para 3.18 • Other Method The method selected to determine the arm's length operating results must ... proper.” 27. The four "specific tests" referenced in Lintas proof of request, rendition, benefit and market comparability are essential and consequently, adopting the CUP method and fixing a NIL price is not merely permissible; it is mandated by the only tribunal authority directly on point. The OECD Transfer-Pricing Guidelines

DCIT-14(1)(2), Mumbai vs. M/S. Ekta Everglade Homes Pvt Ltd., Mumbai

In the result, the ground raised by the revenue is allowed

ITA 1489/MUM/2023[2016-17]Status: DisposedITAT Mumbai24 Nov 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri

For Appellant: Shri Shobit MishraFor Respondent: Ms. Neena Jeph (CIT DR)
Section 143(3)Section 153ASection 250Section 92C

duly extracted below:- “4. Transfer Pricing Issue: The decision of Ld. CIT(A) not acceptable on following grounds: 4. 1. The assessee used CUP method for benchmarking and considered USD industrial yields pertaining to the US economy and not of India. The assessee did not make any efforts to find

DCIT-14(1)(2), Mumbai vs. M/S. Ekta Everglade Homes Pvt Ltd., Mumbai

In the result, the ground raised by the revenue is allowed

ITA 1488/MUM/2023[2015-16]Status: DisposedITAT Mumbai24 Nov 2025AY 2015-16

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri

For Appellant: Shri Shobit MishraFor Respondent: Ms. Neena Jeph (CIT DR)
Section 143(3)Section 153ASection 250Section 92C

duly extracted below:- “4. Transfer Pricing Issue: The decision of Ld. Cit(A) not acceptable on following grounds: 4. 1. The assessee used CUP method for benchmarking and considered USD industrial yields pertaining to the US economy and not of India. Assessee did not make any efforts to find

DCIT, Cir-14(1)(2), Mumbai vs. M/S. Ekta Eveglade Homes Pvt Ltd., Mumbai

In the result, the ground raised by the revenue is allowed

ITA 1486/MUM/2023[2013-14]Status: DisposedITAT Mumbai24 Nov 2025AY 2013-14

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

For Appellant: Shri Shobit MishraFor Respondent: Ms. Neena Jeph (CIT DR)
Section 143(3)Section 153ASection 250Section 92C

same is duly extracted below:- “4. Transfer Pricing Issue: The decision of Ld. CIT(A) not acceptable on following grounds: 4.1. The assessee used CUP method for benchmarking and considered USD industrial yields pertaining to the US economy and not of India. The assessee did not make any efforts

DCIT Circle 1(1), New Delhi vs. Acme Tele Power Ltd. (Now Known As Acme Cleantech Solution Ltd.), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 1074/DEL/2023[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

account of determination of Arm's Length Price for Interest on outstanding receivables and that too by applying external CUP method and further erred in observing that the outstanding receivables is a separate international transaction a per explanation 1(C) to section 92B which has to be benchmarked separately

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3641/DEL/2017[2011-12]Status: DisposedITAT Delhi20 Nov 2025AY 2011-12

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

account of determination of Arm's Length Price for Interest on outstanding receivables and that too by applying external CUP method and further erred in observing that the outstanding receivables is a separate international transaction a per explanation 1(C) to section 92B which has to be benchmarked separately

M/S. Acme Cleantech Solutions Ltd., New Delhi vs. Addl. CIT, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4478/DEL/2016[2010-11]Status: DisposedITAT Delhi20 Nov 2025AY 2010-11

Bench: Shri Sudhir Pareek & Shri Manish Agarwal[Assessment Year : 2011-12] M/S. Acme Cleantech Solutions Vs Dcit, Ltd., C/O-M/S. Rra Taxindia, Circle-1(2) D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] M/S. Acme Cleantech Solutions Vs Addl.Cit, Ltd., C/O-M/S. Rra Taxindia, Range-1 D-28, South Extension, Part-1, New Delhi New Delhi-110049 Pan-Aaeca0914A Appellant Respondent [Assessment Year : 2010-11] Dcit, Vs M/S. Acme Tele Power Ltd. Circle-1(1) [Now, Known As M/S. Acme New Delhi Cleantech Solutions Ltd.] C/O-M/S. Rra Taxindia, D-28, South Extension, Part-1, New Delhi-110049 Pan-Aaeca0914A Appellant Respondent

Section 143(3)Section 144C(13)Section 14ASection 92BSection 92C

account of determination of Arm's Length Price for Interest on outstanding receivables and that too by applying external CUP method and further erred in observing that the outstanding receivables is a separate international transaction a per explanation 1(C) to section 92B which has to be benchmarked separately

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 144Section 144CSection 144C(5)Section 92C

Ld.AR that the ALP cannot 15 M/s. Lintas India Private Limited be determined at Nil, the Ld. DR submitted that the TPO has applied CUP method and has accordingly arrived at the ALP to be Nil for the reason that no independent party would have paid for such services

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

ITA 4828/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Nov 2025AY 2020-21

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

Section 143(3)Section 144BSection 144C(1)Section 144C(13)Section 144C(5)Section 270ASection 40Section 92C

better or more appropriate ALP on the facts of the case 4.4 Rejecting the economic analysis ('at cost Principle') undertaken by the appellant using CUP method as the most appropriate method to determine the arm's length price for provision of technical services in relation to upstream/E&P business ... consortium member (including the assessee) to any other consortium member; and • the transaction has been benchmarked by the assessee under the Comparable Uncontrolled Price (CUP) method, treating the at-cost remuneration model followed by other consortium partners as an internal or quasi-external CUP. 52. The adjustment was computed