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―82. There is considerable tax literature and text that CUP Method,
i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale
Price Method and CP Method, i.e. Cost Plus Method can be applied
to a transaction or closely linked, or continuous transactions. Profits
Split Method and TNM Method grouped as ‗transactional profit
methods', can be equally effective and reliable when applied to
closely linked or continuous transactions. Thus, it would be
inappropriate to proceed with the arm's length computation
methods, with a pre-conceived suppositions on singularity as a
statutory mandate. Clubbing of closely linked, which would include
continuous transactions, may be permissible and not ostracized.
Aggregation of closely linked transactions or segregation by the
assessed should be tested by the Assessing Officer/TPO on the
benchmark and the exemplar; whether such aggregation/
segregation by the assessed should be interfered in terms of the
four clauses stipulated in Section 92C(3) of the Act, read with the
Rules. It would, among other aspects, refer to the method adopted
and whether reliability and authenticity of the arm's length
determination is affected or corrupted.