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| The Tax Publishers2020 TaxPub(DT) 0751 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
In case of distribution or marketing activities when goods were purchased from associated entities and sale were effected to unrelated parties without any further processing, then, RPM (resale price method) was most appropriate method to determine ALP of said transaction.
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Transfer pricing - Determination of ALP - MAM - RPM v. TNMM--Re-sale of goods imported from AE without any value addition
Assessee was engaged in distribution of information and communication equipments such as printers and facsimile machines imported from its AE. It adopted RPM as the most appropriate method (MAM) to benchmark said international transaction. TPO applied TNMM and accordingly suggested TP adjustment. Held: In case of distribution or marketing activities when goods were purchased from associated entities and sale were effected to unrelated parties without any further processing, then, RPM (resale price method) was most appropriate method to determine ALP of said transaction.
Relied:CIT v. L' Oreal India Pvt. Ltd. (2015) 53 Taxmann.com 432 (Bom) : 2015 TaxPub(DT) 565 (Bom-HC), Mattel Toys (I) Pvt. Ltd. v. Dy. CIT (2014) 30 ITR (T) 283 (Mum-Trib.) : 2013 TaxPub(DT) 2260 (Mum-Trib) and Asstt. CIT v. L' Oreal India Pvt. Ltd. in ITA No, 823/Mum/2010 of dt. 31-10-2012.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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