Higher price paid to AEs accepted as ALP under the CUP Method, provided there is sufficient economic and commercial justification evidencing the same

Court :Mumbai Bench of the Income-tax Appellate Tribunal Citation :Cheminova India Ltd Vs ACIT, Mumbai (ITA No. 4865/Mum/05) [13 ITAT INDIA 240 (Mum)] Brief : Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (‘the Tribunal’) in the case of Cheminova India Ltd Vs ACIT, Mumbai (ITA No. 4865/Mum/05) [13 ITAT INDIA 240 (Mum)]., accepted higher price paid to its Associated Enterprises (‘AEs’) (as compared to unrelated parties) under Comparable Uncontrolled Price (‘CUP’) Method to be the arm’s length price (‘ALP’) based on the economic and commercial justification. F...