Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2017 (11) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (11) TMI 1655 - HC - Income TaxTPA - selection of MAM - value addition made before re-selling the particular products (i.e. the SIM cards) - Held that:- There was no error in law committed by the ITAT when it held that RPM was the Most Appropriate Method in case of distribution or marketing activities especially when goods are purchased from associated entities and there are sales effected to unrelated parties without any further processing. Therefore, a contrario, when the reseller does not add any value to the product of the goods, the RP method would be appropriate for determining the arms' length price. See Nokia India (P) Ltd. v. Dy. CIT [2014 (11) TMI 101 - ITAT DELHI] ITAT committed no error in law in applying RPM as the Most Appropriate Method for computing the arms' length price.
|