Transfer Pricing- CUP method (the traditional transaction method) is preferable to the other methods

In principle, the CUP method (the traditional transaction method) is preferable to the other methods because all other things being equal, the CUP and traditional transactional methods lead to more reliable results vis-a-vis the results  obtained by applying transaction profit method. For the CUP method, the focus is on the market in which the products are sold by the assessee and any unique feature of the market in which assessee is situated is of no importance in relative terms.

IN THE INCOME TAX APPELLATE TRIBUNAL

(DELHI BENCH ‘B’ NEW DELHI)

M/s Clear Plus India Pvt. Ltd., Vs. Dy. C.I.T.

I.T.A. No. 3944/D/2010 Assessment year: 2006- 07

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