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| The Tax Publishers2020 TaxPub(DT) 4419 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Where assessee assembled the goods partly purchased from its AE abroad and partly developed by its own vendor and sold finished goods to third parties and it was not the case that assessee resold the same goods with only minor modifications to justify adoption of RPM as the most appropriate method, TPO was justified in adopting TNMM method as the MAM.
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Transfer pricing - Determination of ALP - Selection of MAM - RPM v. TNMM assessee assembled the goods partly purchased from AE abroad and partly developed by its own vendor for sale to third parties
Assessee assembled the goods partly purchased from its AE abroad and partly developed by its own vendor and sold finished goods to third parties. To benchmark said international transaction, assedssee adopted RPM as the MAM. TPO considered TNMM as the MAM and thus suggested ALP adjustment.Held: It was not the case that assessee resold the same goods with only minor modifications to justify adoption of RPM as the most appropriate method. In such situation, TPO was justified in adopting TNMM method as the MAM.
REFERRED :
FAVOUR : Against the assessee.
A.Y. : 2012-13
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