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 Int

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