Most appropriate method for determining Arm’s Length Price is internal CUP

Global Green Company Ltd Vs DCIT (ITAT Delhi) Held that internal CUP [internal Comparable Uncontrolled Price Method] is the most appropriate method for undertaking the determination of Arm’s Length Price. Facts- Global Green Company Limited (GGCL) is engaged in the business of ‘processing and export of pickled Gherkins (Baby cucumber). 68.8% of the shares of the assessee company are held by M/s Bilt Trading & Infrastructure Pvt. Ltd. In turn, the assessee is a 100% holding company of Tiffy International BV(Tiffy), with whom it had undertaken international transactions. The assessee com...