royalty
payment and also rejected the assessee‟s contention
regarding Internal CUP which was available in the case of the
assessee with similar agreement with ... aside to the file of the TPO to examine the
Internal CUP. He also brought to our notice that, in the
assessment year
assessee had benchmarked the
guarantee fees on the basis of an Internal CUP i.e as per the average of the
guarantee fees that ... submitted by the ld. A.R that the Internal CUP
adopted by the assessee for benchmarking the transaction of providing
guarantee fees was rejected
broadly classified into two categories i.e. Internal CUP
Method & External CUP Method. Under the Internal CUP Method, the
transaction between the AEs involving ... circumstances it Is noted
that reliable internal CUP data was available with the appellant to
benchmark the ALP of the power generated & supplied
length prices
on the basis of such internal CUP inputs, the adjustments are made in sale prices of Cetyl
Pyridinium Chloride ... CUP inputs. In essence, his
submission is, that CUP method is the most appropriate method on the facts of this case, that
sufficient internal CUP
Board
9 JSW Power 27 3.15 Intern 9 Indian 1628 3.84 Intern
Trading Co. al Energy al
Ltd CUP Exchange CUP
Ltd
10 Adani Power ... CUP
13 Jindal Steel 44 4.67 Intern 13 Dhariwal 1 4.2 Intern
and Power Ltd al Infrastructu al
CUP re Ltd. CUP
14 The Brihan
case here.
Further, academically, the CUP can be internal or external. Internal
CUP, being the comparability of the similar transaction between the
assessee ... None of the
CUPs used by the TPO falls within the said definition of external
CUP. Thus, there are no 'internal CUP
broadly classified into two categories i.e. Internal CUP
Method & External CUP Method. Under the Internal CUP Method, the transaction
between the AEs involving ... classified into two
categories i.e. internal CUP method and external CUP method. Under internal CUP
method the transactions between the AE's involving
deviating
from the stand taken in the earlier
years in which internal CUP method was
adopted for benchmarking the sale to the
AEs, computed ... effect thus, the assessee moved, in
the current year, from internal CUP to
TNMM. This, however, did not find favour
with
which power was supplied and
purchased by the SEBs as an internal CUP since 1997-98 and therefore,
the said rates were required ... purchased power from SEBs, could be considered as an internal CUP.
The DRP held that only the rates at which the petitioner had sold power
broadly
classified into two categories i.e. Internal CUP Method &
External CUP Method. Under the Internal CUP Method, the
transaction between the AEs involving ... classified
into two categories i.e. internal CUP method and external CUP
method. Under internal CUP method the transactions between
the AE's involving
