Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (3) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (3) TMI 426 - AT - Income TaxTP Adjustment - adjustment of AMP expenditure - method to be adopted for benchmarking the trading transactions - RPM v/s TNMM - assessee had benchmarked its trading segment by adopting “Resale Price Method” as the most appropriate method - HELD THAT:- There is no dispute with regard to the fact that the assessee does not make any value addition to the products imported by it from its AE. When there is no value addition and the imported products are sold as it is, then “Resale Price method” is held to be most appropriate method in the cases relied upon by Ld A.R. Resale Price Method is most appropriate method in the facts and circumstances of the present case. Accordingly we direct the AO/TPO to adopt Resale Price Method as most appropriate method and determine the ALP of the transactions accordingly. Validity of Transfer pricing adjustment made in respect of AMP expenses - Following the decision rendered in AY 2012-13 in the assessee’s own case [2019 (5) TMI 1541 - ITAT BANGALORE] we hold that no adjustment needs to be done in respect of AMP expenses and accordingly direct the AO to delete the impugned addition.
|