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CUP method not applicable where assessee made purchases from AEs and non-AEs with huge difference in quantities and price
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CUP method not applicable where assessee made purchases from AEs and non-AEs with huge difference in quantities and price
Posted on
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January 25, 2020
Tenet Tax Daily January 25 2020
By
tenettax-team
International Tax
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Mere issuance of a show-cause notice cannot be equated and treated as a draft assessment order as same would make provisions of section 144C redundant
Based on FAR analysis where it is determined that foreign AE is a non-complex entity, it could be taken as tested party for benchmarking purposes
