Taxpayer’s previous year transactions cannot be used as CUP benchmark
March 02, 2011
Sophie Ashley - TPW
The Mumbai Income Tax Appellate Tribunal (ITAT) has ruled that a taxpayer’s past transactions cannot be used as a comparable uncontrolled price (CUP) for the purpose of benchmarking a transaction.
The taxpayer, NGC Network India, is a broadcasting company engaged in the distribution and marketing of the National Geographic Channel and the Adventure One Channel and the supply of post production services to media companies.
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