63 results for “transfer pricing”+ Section 42clear
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In the result, these appeals are dismissed and the substantial
Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)
transfer price of power under the CUP method. The CIT(A) noted Rule 10B of the Income Tax Rules and particularly Clause (a) of Sub Rule 1 of Rule 10B which explains Comparable Uncontrolled Price (CUP) method. In terms of the said rule, the application of CUP method requires strict product comparability which has been transacted under similar conditions. This