CUP method consistently followed to bench mark transaction with AE cannot be unreasonably rejected

Mega Soft Ltd Vs DCIT (ITAT Chennai) ITAT Chennai held that TPO unreasonably rejected the CUP method consistently followed by the assessee to bench mark international transaction with its Associated Enterprise as there was no change in the facts and circumstance of the case for the impugned Assessment Year. Facts- During the year under consideration, the assessee has entered into various international transactions with its AEs. The assessee has selected CUP as most appropriate method and bench marked transactions with its AE and claimed to be a tested party. During the course of assessment pro...