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| The Tax Publishers2020 TaxPub(DT) 0024 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
In case of assessee who was a pure distributor of goods purchased from its AE and resold the same to third party without any value addition, RPM was the MAM as against TNMM.
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Transfer pricing - Determiantion of ALP - MAM - RPM v. TNMM--Re-sale of goods procured from AE without any value addition
Assessee procured goods from its AE abroad and resold the same to other parties in India without any value addition. In order to benchmark its iternational transactiosn qua trading segment assessee considered RPM as the most appropriate method (MAM). However, TPO applied TNMM method and accordingly, suggested TP adjustment.Held: In case of assessee who was a pure distributor of goods purchased from its AE and resold the same to third party without any value addition, RPM was the MAM as against TNMM.
Relied:Oriflame India (P) Ltd. v. Asstt. CIT, TS 673-ITAT-2017 (Del-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2009-10
INCOME TAX ACT, 1961
Section 92C
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