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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

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. Zf Wind Power Coimbatore Private Limited, Coimbatore

ITA 246/CHNY/2025[2013]Status: DisposedITAT Chennai01 Aug 2025

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 245 & 246/Chny/2025 निर्धारण वर्ष/Assessment Years:2012-13 & 2013-14 & C.Ο No.21/Chny/2025 [In I.T.A. No.245/Chny/2025] The Joint Commissioner Of Income Tax (Osd), Corporate Circle 1, Coimbatore Vs. Zf Wind Power Coimbatore Pvt. Ltd., Plot No.3, Hi Tech Engineering & Service Sector Sez, Annur Road, Village Kittampalayam & Karumathampatty, Coimbatore – 641 659. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent/Cross Objector) राजस्व की ओर से /Revenue By : Shri P.K. Senthil Kumar, Addl.Cit निर्धारिती की ओर से/Assessee By : Shri Ashik Shah, Ca & Ms. Soundariya, Ca सुनवाई की तारीख/Date Of Hearing : 15.07.2025 घोषणा की तारीख/Date Of Pronouncement : 01.08.2025 आदेश /O R D Er Per George George K: These Appeals Filed By The Revenue Are Directed Against Two Orders Of The Commissioner Of Income Tax (Appeals), Chennai-16 Both Dated 28.11.2024 Passed U/S.250 Of The Income Tax Act (Hereinafter The 'Act'). The Relevant Assessment Years Are 2012-13 & 2013-14. The Assessee Has Also Filed Cross Objection For

For Appellant: Shri Ashik Shah, CA &For Respondent: Shri P.K. Senthil Kumar, Addl.CIT
Section 143(2)Section 144C(4)Section 250Section 92C

payment on Fully Compulsory Convertible Debentures ("FCCDs"), the TPO rejected the TP analysis of the assessee company wherein assessee had adopted Comparable Uncontrolled Price ('CUP') method as most appropriate method. The assessee in its TP analysis had stated that its interest rate on debentures at 13.50% was lower than

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. Zf Wind Power Coimbatore Private Limited, Coimbatore

ITA 245/CHNY/2025[2012]Status: DisposedITAT Chennai01 Aug 2025

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 245 & 246/Chny/2025 निर्धारण वर्ष/Assessment Years:2012-13 & 2013-14 & C.O No.21/Chny/2025 [In I.T.A. No.245/Chny/2025] The Joint Commissioner Of Income Tax (Osd), Corporate Circle 1, Coimbatore Vs. Zf Wind Power Coimbatore Pvt. Ltd., Plot No.3, Hi Tech Engineering & Service Sector Sez, Annur Road, Village Kittampalayam & Karumathampatty, Coimbatore – 641 659. (अपीलार्थी/Appellant) राजस्व की ओर से /Revenue By निर्धारिती की ओर से/Assessee By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement Pan: Aabch 8089G (प्रत्यर्थी/Respondent/Cross Objector) : Shri P.K. Senthil Kumar, Addl.Cit : Shri Ashik Shah, Ca & Ms. Soundariya, Ca : 15.07.2025 : 01.08.2025 आदेश /Order Per George George K: These Appeals Filed By The Revenue Are Directed Against Two Orders Of The Commissioner Of Income Tax (Appeals), Chennai-16 Both Dated 28.11.2024 Passed U/S.250 Of The Income Tax Act (Hereinafter The 'Act'). The Relevant Assessment Years Are 2012-13 & 2013-14. The Assessee Has Also Filed Cross Objection For

Section 143(2)Section 144C(4)Section 250Section 92C

payment on Fully Compulsory Convertible Debentures ("FCCDs"), the TPO rejected the TP analysis of the assessee company wherein assessee had adopted Comparable Uncontrolled Price ('CUP') method as most appropriate method. The assessee in its TP analysis had stated that its interest rate on debentures at 13.50% was lower than

Ambattur Clothing Limited, Chennai vs. DCIT Company Circle 1(1), Chennai

ITA 1957/CHNY/2017[2013-14]Status: DisposedITAT Chennai31 Jul 2025AY 2013-14

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1957/Chny/2017 निर्धारण वर्ष / Assessment Year: 2013-14 M/S. Ambattur Clothing Ltd [Now Demerged & Known As M/S. Ambattur Fashion India Pvt. Ltd.] No.86/E-2, Ambattur Industrial Estate Ambattur, Chennai– 600 058. (Pan:Aaaca-4127-D) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement The Deputy Commissioner Of Vs. Income-Tax, Corporate Circle -1(1), Chennai. (प्रत्यर्थी/Respondent) Shri. Sp Chidambaram, Advocate. Mr. Arv Sreenivasan, Cit. 09.07.2025 31.07.2025 आदेश /Order Per S. R. Raghunatha, Am : The Present Appeal Is Filed By The Assessee Against The Final Assessment Order Dated 21.06.2017 Of The Deputy Commissioner Of Income Tax, Corporate Circle 1(1) For The Assessment Year 2013-14 Passed In Compliance To Directions Of Dispute Resolution Panel-2, Bengaluru (Drp) Vide Order Dated 11.05.2017. 2. The Brief Facts Of The Case Are That The Assessee Is A Company Engaged In The Business Of Manufacturing & Sale Of Readymade Garments To Ae & Non- Ae'S. The Assessee Filed Its Return Of Income For The A.Υ.2013-14 On 30.11.2013 Declaring A Total Income Of Rs.11,57,20,670/-. The Case Was Selected For Scrutiny Through Cass & Accordingly Statutory Notices Were Issued To The Assessee. A :-2-:

Section 92C

garments, Sale of machinery, Sale of intangible asset designs, sale of spares, reimbursement. The Assessee in its TP documentation benchmarked these international transactions under CUP method. The TPO in the Transfer Pricing Order has observed the following: "Purchase and sale of raw materials: The Assessee submitted that the extra stock ... available with itself and the AE are bought and sold at cost and thus the transaction is justified under CUP method. The assessee has adopted CUP as the MAM and has submitted that it requires to purchase only from accredited customer certified vendors in which case had the same

Firmenich Aromatics Production (India) Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 1(3)(1), Mumbai

ITA 6100/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Jul 2025AY 2021-22

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Ms. Ramapriya Raghavan, CIT DR
Section 144C(5)

ΤΡΟ. 1.3 That on the facts and circumstances of the case and in law, the Ld. TPO has erred in applying Comparable Uncontrolled Price ('CUP') method to benchmark the impugned transaction with respect to the common finished goods sold to both Associated Enterprises ('AEs') and Non-AEs. 1.4 Without prejudice ... differences on account of geographical market, volume of transactions, functional and risk profile of the parties involved and level of market while applying the CUP method. The Ld. AO/DRP have further erred in upholding the action of the Ld. ΤΡΟ. 1.5 That on the facts and circumstances of the case

Firmenich Aromatics Production (India) Private Limited, Mumbai vs. Assessing Officer, New Delhi

ITA 3987/MUM/2024[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Smt. Beena Pillai & Shri Girish Agrawal

Section 144C(5)

ΤΡΟ. 1.3 That on the facts and circumstances of the case and in law, the Ld. TPO has erred in applying Comparable Uncontrolled Price ('CUP') method to benchmark the impugned transaction with respect to the common finished goods sold to both Associated Enterprises ('AEs') and Non-AEs. 1.4 Without prejudice ... differences on account of geographical market, volume of transactions, functional and risk profile of the parties involved and level of market while applying the CUP method. The Ld. AO/DRP have further erred in upholding the action of the Ld. ΤΡΟ. 1.5 That on the facts and circumstances of the case

Dow Chemical International, Mumbai vs. Addl /Joint/Dy. /Asstt Comm of Income Tax /ITO, Mumbai

The appeal is dismissed as withdrawn

ITA 1940/MUM/2021[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri, Accou Ntant Member आयकर अपील सुं./Ita No. 1940/Mum/2021 (नििाारण वर्ा / Assessment Year: 2016-17) Dow Chemical V/S. The Dcit/Acit, Ward International Private बिाम 14(1)(2), Mumbai Limited The Godrej It Park, P2, 1St Additional/Joint/Deputy Floor, Block B, 02 Lbs /Assistant Commissioner Of Road, Godrej Business Income Tax/Income District Phirojshanagar, Tax Officer, National Vikhroli (W), Mumbai E-Assessment Centre, Delhi 400079 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacd4467B Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Hitesh Thakkar राजस्व की ओर से /Revenue By: Shri Bhagirath Ramawat Sr Dr

For Appellant: Shri Hitesh ThakkarFor Respondent: Shri Bhagirath Ramawat SR DR
Section 143(3)Section 144C(13)Section 153Section 92C

price of the international transaction of export of finished goods, without providing any cogent reasons for the same. Inappropriate application of Comparable Uncontrolled Price ('CUP") method to benchmark the international transaction 6. Erred in considering CUP method as the most appropriate method for determination of arm's length price without ... functions performed, risks assumed, geographical considerations, business reasons for sale of products etc. which in the present case cannot be reasonably quantified and hence CUP method cannot be applied. 8. Erred in not considering 15% volume discount for computation of adjustment, though the same was granted

Deputy Commissioner of Income Tax- 3(1)(1), Mumbai vs. Dsv Solutions Pvt. Ltd. (Formerlyut Worldwide (India) Pvt. Ltd.), Mumbai

In the result, the appeals filed by the revenueand cross

ITA 534/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

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

Section 37Section 92F

assessee benchmarked the payment made and received towards freight forwarding concerning the AE's in various countries, applying the internal Comparable Uncontrolled Price(CUP)method. The assessee compared the profit share percentage given to AE's with profit share percentage given to unrelated entities for both export and import business ... Ld.TPO observed that the assessee had not benchmarked the payment made and received towards freight forwarding and reimbursement of expenses applying CUP method. The assessee was thus called upon to justify as to how the above transactions can be treated to be at arms length. In response, the assessee submitted

Deputy Commissioner of Income Tax- 3(1)(1), Mumbai vs. Dsv Solutions Pvt. Ltd. (Formerly Ut Worldwide (India) Pvt. Ltd.), Mumbai

In the result, the appeals filed by the revenueand cross

ITA 533/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2025AY 2013-14

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

Section 37Section 92F

assessee benchmarked the payment made and received towards freight forwarding concerning the AE's in various countries, applying the internal Comparable Uncontrolled Price(CUP)method. The assessee compared the profit share percentage given to AE's with profit share percentage given to unrelated entities for both export and import business ... Ld.TPO observed that the assessee had not benchmarked the payment made and received towards freight forwarding and reimbursement of expenses applying CUP method. The assessee was thus called upon to justify as to how the above transactions can be treated to be at arms length. In response, the assessee submitted

Deputy Commissioner of Income Tax- 3(1)(1), Mumbai vs. Dsv Solutions Pvt. Ltd. (Formerly Ut Worldwide (India) Pvt. Ltd.), Mumbai

In the result, the appeals filed by the revenueand cross

ITA 532/MUM/2025[2012-13]Status: DisposedITAT Mumbai30 Jul 2025AY 2012-13

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

Section 37Section 92F

assessee benchmarked the payment made and received towards freight forwarding concerning the AE's in various countries, applying the internal Comparable Uncontrolled Price(CUP)method. The assessee compared the profit share percentage given to AE's with profit share percentage given to unrelated entities for both export and import business ... Ld.TPO observed that the assessee had not benchmarked the payment made and received towards freight forwarding and reimbursement of expenses applying CUP method. The assessee was thus called upon to justify as to how the above transactions can be treated to be at arms length. In response, the assessee submitted

Portescap India Private Limited, Mumbai vs. DCIT Circle 2(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly allowed

ITA 6749/MUM/2024[2021-22]Status: DisposedITAT Mumbai28 Jul 2025AY 2021-22

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 143(3)Section 153Section 92C(3)

transactions. In the absence of similar genre, the Ld.TPO would be justified to benchmark the transactions of payment of management services separately under CUP method regardless of TNMM method adopted for other services received from AE’s. He thus strongly supported the observations of the Ld.TPO and refer to relevant

Teejay India Private Limited, Visakhapatnam vs. Deputy Commissioner of Income Tax, Circle-5(1), Visakhapatnam

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

ITA 340/VIZ/2024[2020-21]Status: DisposedITAT Visakhapatnam25 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.340/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2020-21) & S.A. No. 15/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2020-21) Teejay India Private Limited, Vs. Deputy Commissioner Of Plot No. 15, Brandix, Apsez, Income Tax, Pudimadaka Road, Atchutapuram Circle-5(1), Mandal, Visakhapatnam-530011. Visakhapatnam. Pan: Aaaco9452H (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Sri Darpan Kirpalani, AdvocateFor Respondent: Dr. Satyasai Rath, CIT(DR)
Section 142(1)Section 143(2)Section 143(3)Section 144C(5)Section 92C

grounds relate to disallowance of royalty paid to Teejay Lanka PLC. On this issue, the Ld. AR submitted that the assessee has adopted the CUP method for benchmarking the transactions with respect to the payment of royalties. However, he submitted that the Ld. TPO / DRP has concluded that there

Signode India Limited, Hyderabad vs. ACIT., Circle 3(1), Hyderabad

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

ITA 1376/HYD/2024[2021-22]Status: DisposedITAT Hyderabad25 Jul 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri H. Srinivasulu, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 143(3)Section 144BSection 144C(13)Section 153Section 92C(3)

have referred to the PLR rates only by way of analogy so as to state the prevailing interest rates in India, but while applying CUP method for comparability, they had applied LIBOR rates prevailing and had applied a mark-up of 700 points on account of low credit rating

M/S. Laxmi Organic Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

ITA 4782/MUM/2024[2020-21]Status: DisposedITAT Mumbai25 Jul 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Percy Pardiwala, Sr. Advocate andFor Respondent: Ms. Neena Jeph, CIT DR
Section 144C(5)Section 80I

material to support the same, (k) in not appreciating that to ascertain the arm's length price of the specified domestic transactions under the CUP method, it is incumbent upon the authorities to examine the correctness of such arm's length price under the CUP method, without having regard ... increasing the disallowance made by the ld. TPO of Rs.7,79,97,476/- to Rs.21,44,93,066/-. 11. 1. It is noted that CUP method taken by the assessee as the most appropriate method (MAM) was rejected solely on the ground that the Functions, Assets, Risks (FAR) analysis

ACIT, Circle - 2(1), Kolkata vs. M/S. Bata India Ltd., Kolkata

Appeal is partly allowed and the CO is dismissed

ITA 1844/KOL/2017[2009-10]Status: DisposedITAT Kolkata23 Jul 2025AY 2009-10

Bench: the Hon'ble Income Tax Appellate Tribunal, Kolkata in ITA No. 1844/Kol/2017 for the assessment year 2009-10;

Section 143(3)Section 250Section 43B

distinguishable from AY 2004-05 since the assessee has relied on ITAT’s order for AY 2004-05. The distinguishing features are mainly that CUP method was used for AY 2004- 6 CO No. 124/Kol/2017 Bata India Limited 05 while TNMM method was used ... been held that stewardship activities do not constitute services and there cannot be any charge for the same. (iii) The CUP method has been rightly adopted considering OECD guidelines which say that ALP should be worked out on a transaction-by- transaction basis and also CUP being a direct method

M/S. Tbea Shenyang Trasformer Gropup Company Limited, Vadodara vs. The Deputy Commissioner of Income Tax, Int. Tax., Vadodara

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

ITA 581/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad22 Jul 2025AY 2012-13

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleआयकर अपील सं./I.T.A. No. 581/Ahd/2017 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ M/S. Tbea Shenyang Deputy Commissioner Of Transformer Group Income Tax Vs. Company Limited International Taxation, National Highway No.-8, Vadodara Villae : Miyagam, Karja, Vadodara, Gujarat - 390007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadct4557F (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Arpit Jain, Ar ""यथ" क" ओर से/Respondent By : Shri Mahesh Shah, Cit. Dr 24/04/2025 Date Of Hearing Date Of Pronouncement 22/07/2025 O R D E R Per Smt. Annapurna Gupta, Am:

For Appellant: Shri Arpit Jain, ARFor Respondent: Shri Mahesh Shah, CIT. DR
Section 143(3)Section 9Section 92C

China. The same was confirmed by the DRP. 30. The solitary argument of the Ld. Counsel for the assessee before us was that the CUP method was the most appropriate method to be applied in the present case with the contract entered into for the onshore activities by the head ... Length Price, we find that the Assessing Officer applied the TNMM method; whereas, the learned CIT(A) has held that the CUP method is most appropriate method. Learned CIT(A), while deciding that the CUP method is the most appropriate method, as pleaded by the assessee, observed following findings

Ivy Software Development Services Private Limited, Hyderabad vs. DCIT, Circle -2(1), Hyderabad

In the result, the ground no

ITA 73/HYD/2022[2017-18]Status: DisposedITAT Hyderabad16 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(2)Section 143(3)Section 144C(5)

have referred to the PLR rates only by way of analogy so as to state the prevailing interest rates in India, but while applying CUP method for comparability, they had applied LIBOR rates prevailing and had applied a mark-up of 700 points on account of low credit rating

M/S Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 2539/DEL/2017[2005-06]Status: DisposedITAT Delhi16 Jul 2025AY 2005-06

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

order passed under section 92CA(3) of the Act determined the arm's length price of international transactions of export of float glass, applying CUP method as against the TNMM applied by the assessee, holding that in the case of the assessee, same products have been sold to unrelated parties ... most suitable method for benchmarking the sale price to associated enterprise. 3.3 The TPO, for the purpose of computing the ALP, has applied CUP method as the most appropriate method, and has adopted following methodology for selection of the comparable uncontrolled transactions: (i) The sales made to associated enterprises

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 5358/DEL/2010[2006-07]Status: DisposedITAT Delhi16 Jul 2025AY 2006-07

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

order passed under section 92CA(3) of the Act determined the arm's length price of international transactions of export of float glass, applying CUP method as against the TNMM applied by the assessee, holding that in the case of the assessee, same products have been sold to unrelated parties ... most suitable method for benchmarking the sale price to associated enterprise. 3.3 The TPO, for the purpose of computing the ALP, has applied CUP method as the most appropriate method, and has adopted following methodology for selection of the comparable uncontrolled transactions: (i) The sales made to associated enterprises

Gujrat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 4856/DEL/2010[2004-05]Status: DisposedITAT Delhi16 Jul 2025AY 2004-05

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singhsl.No. Ita No. Filed By Assessee/Revenue Assessment Year Authority Passing The Order

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

order passed under section 92CA(3) of the Act determined the arm's length price of international transactions of export of float glass, applying CUP method as against the TNMM applied by the assessee, holding that in the case of the assessee, same products have been sold to unrelated parties ... most suitable method for benchmarking the sale price to associated enterprise. 3.3 The TPO, for the purpose of computing the ALP, has applied CUP method as the most appropriate method, and has adopted following methodology for selection of the comparable uncontrolled transactions: (i) The sales made to associated enterprises

ACIT, New Delhi vs. M/S Gujarat Guardian Ltd., New Delhi

ITA 4791/DEL/2010[2004-05]Status: DisposedITAT Delhi16 Jul 2025AY 2004-05

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

order passed under section 92CA(3) of the Act determined the arm's length price of international transactions of export of float glass, applying CUP method as against the TNMM applied by the assessee, holding that in the case of the assessee, same products have been sold to unrelated parties ... most suitable method for benchmarking the sale price to associated enterprise. 3.3 The TPO, for the purpose of computing the ALP, has applied CUP method as the most appropriate method, and has adopted following methodology for selection of the comparable uncontrolled transactions: (i) The sales made to associated enterprises