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| The Tax Publishers2020 TaxPub(DT) 0788 (Jp-Trib) : (2020) 204 TTJ 0371 INCOME TAX ACT, 1961
Section 92C
Since transactions of purchases of polypropylene and Tafmer were also representing purchases made by AE from third party and supply to assessee without any value addition, therefore, these two transactons were in the nature of trading in the land of AE without any value addition, and were to be tested by applying CPM as MAM as was applied by assessee in preceding years and also accepted by TPO.
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Transfer pricing - Determination of ALP - MAM - CUP/CPM v. TNMM--Transaction of import of goods from AE representing trading in AE's hands
Assessee imported Polypropylene and Tafmer from its AE, which AE itself had purchased from unrelated party. Assessee benchmarked said international transaction by applying Cost Plus Method (CPM) as Most Appopriate Method (MAM).TPO considered TNMM as the MAM and accordingly suggested TP adjustment.Held: Since transactions of purchases of polypropylene and Tafmer were also representing purchases made by AE from third party and supply to assessee without any value addition, therefore, these two transactons were in the nature of trading in the land of AE without any value addition, and were to be tested by applying CPM as MAM as was applied by assessee in preceding years and also accepted by TPO.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 92C
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