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Methods for determination of – Rule 10B : Where assessee provided management consultancy services to its AEs and to unrelated parties and applied CUP method comparing hourly rate charged to AEs and Non-AE, to justify Internal CUP, since assessee had earned significantly higher profit margins in AE segment vis-à-vis non-AE segment, internal TNMM was to be given preference over external TNMM analysis, however since CUP applied by assessee did not have any flaw or error, same was to be accepted – The Boston Consulting Group (India) (P.) Ltd. v. Deputy Commissioner of Income-tax – [2024] 162 271 (Mumbai – Trib.)



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