CUP is most appropriate method for determining ALP for importing goods for manufacturing segment

Lenovo (India) Pvt Ltd Vs ITO (ITAT Bangalore) ITAT Bangalore held that Comparable Uncontrolled Price (CUP) is the most appropriate method for determining the Arm’s Length Price of the assessee for the importing of goods for manufacturing segment. Facts- The assessee company is engaged in the business of trading, manufacture and sale of desktops, lap tops, servers and smart phones. The case was selected for scrutiny through CASS for complete scrutiny. Accordingly, statutory notices were issued to the assessee and various details were called for. In response to notice issued, the assessee com...