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2020 (12) TMI 1366 - AT - Income TaxTP Adjustment - MAM selection for distribution segment - assessee has taken Resale Price Method (RPM) to anlayse the segment - TPO said that RPM method can be used only for pure traders who do not do any local value addition - HELD THAT:- In this case, the TPO himself has recorded that the assessee manufactured goods at Rs.83,35,010 and traded goods of Rs.1,73,77,415. However he clubbed the entire turnover and applied TNMM method to determine the ALP. With regard to sale of traded goods, it is appropriate to apply the RPM method if there was no value added to the traded goods. In case pure sale of traded goods, RPM method is Most Appropriate Method and it does not involve any manufacturing activity. Accordingly, we remit this issue to the file of AO/TPO with direction to the assessee to furnish the segmented details of sale of traded goods and then the AO/TPO shall apply RPM method in respect of sale of traded goods. This additional ground is partly allowed for statistical purposes.
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