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CUP method couldn’tbe applied if AE & an non-AEs were situated at different geographical locations

June 14, 2019[2019] 106 166 (Mumbai - Trib.)

TRANSFER PRICING : While considering issue of comparability with an uncontrolled transaction, condition prevailing in market for which respective parties to transaction operate, including geographical location along with other factors is relevant to decide which method is suitable for benchmarking said transaction

TRANSFER PRICING : Where TPO had not followed any approved method for determination of arm's length price as prescribed under statutory provisions, keeping in view relevant statutory provisions and principles, TPO was to be directed to delete TP adjustment

TRANSFER PRICING : Arm's length price of interest to be charged on ECB loan availed from AE had to be determined at six months USD LIBOR rate plus 300 basis points as per RBI circular

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