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Most appropriate method for determining Arm’s Length Price is internal CUP
Case Law Details
- Case Name
- Global Green Company Ltd Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2003-04
- Courts
- All ITAT, ITAT Delhi
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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...





