21 results for “transfer pricing”+ Section 45(2)clear
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Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar
45,08,356/-and the same amount was added back by the AO. The Appellant contends that it had adopted Comparable Uncontrolled Price (CUP) method to determine the purchase price from Associated Enterprises (AE) and the same should have been accepted by the AO. It is clear from records that TNMM is the Most Appropriate Method (MAM) for the Appellant