] T/ILT : Where assessee adopted CUP method for determination of ALP in respect of

T/ILT : Where assessee adopted CUP method for determination of ALP in respect of its international transactions and further for benchmaking of price in transactions with AEs it considered internal comparable transactions traded with non AEs involving same products, TPO was wrong in rejecting CUP method adopted by assessee



[2013] 31 taxmann.com 388 (Mumbai - Trib.)

IN THE ITAT MUMBAI BENCH 'K'

Deputy Commissioner of Income-tax, Circle 8(2), Mumbai

v.

Isagro (Asia) Agrochemicals (P.) Ltd.*