cost plus method as stated in its
TP study report. The TPO observed that CUP method requires close
comparability. The CUP method ... adopted cost plus method but in-fact the assessee adopted comparable
uncontrolled prices (CUP) method , wherein it adopted internal CUP method
to benchmark its international
process outsourcing facility in R and
D, Analytical Method Development, stability studies, clinical studies,
validation method etc. valid upto 17-08-2009". The Assistant ... regulatory review. pre-
formulation studies, formula development, analytical
method development, analytical method validation,
packaging development, scale up from lab scale
under taken the accommodation entries LTCG
investigation on a much larger scale than earlier as a result they were
able to identify a very large ... ACIT-22(2)
and beneficiary and this method had yielded results on a limited scale
emanating only from individual/individuals targeted. Therefore, keeping
in mind
observed that
assessee had employed various methods to evade taxes on a large
scale which inter alia included, to facilitate the unaccounted business
and inflation
observed that
assessee had employed various methods to evade taxes on a large
scale which inter alia included, to facilitate the unaccounted business
and inflation
practice, taxation of fringe benefits by the employer-based
disallowance method resulted in large-scale litigation on account
of ambiguity in defining the tax base
road distance and not as per crow's flight , straight line
method. The assessee further stated that the certificate issued by the
Dy. Supdt ... mtrs is based on the scale of map i.e. crow's flight method
therefore cannot be admitted as an evidence. The assessee also
ship management services was scaled down to an amount of USD
2,900 per day. Assessee had applied TNMM method in order to benchmark
Asst Cit (Ltu) 2, Mumbai vs Reliance Industries Ltd, Mumbai on 28 September, 2018
IN
recently acquired. The Courts take the view of inflation has
that the method employed should 'as tended to make
nearly as possible accord with ... small scale. Therefore, considering the ratio in the case of Vallambrosa Rubber Co. Ltd. (supra), we cannot say that this method is not approved
