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2020 (10) TMI 933 - AT - Income TaxTP Adjustment - MAM selection - TNMM or RPM - TPO computing the arm length price in respect of ‘Import of Material’ and ‘Export of finished goods’ by applying Transactional Net Margin Method and rejecting resale Price Method as the most appropriate method, thereby making a TP adjustment - HELD THAT:- In the present case before us the issue is whether the assessee is a distributor or a manufacturer and whether resale price method is applicable to the international transactions entered into by the assessee. It is not the case that assessee has resold the same goods with only minor modifications to justify the adoption of RPM as the most appropriate method. In the present case the assessee has assembled the goods partly purchased from its associated enterprise and partly developed by its own vendor. Therefore, the decision relied upon by the learned authorised representative MSS INDIA (P) LIMITED. [2009 (5) TMI 600 - ITAT PUNE-A]does not help the case of the assessee. In view of the above facts we do not find any infirmity in the order of the learned assessing officer/transfer pricing officer as well as the direction of the learned dispute resolution panel in rejecting the resale price method adopted by the assessee and adopting transactional net margin method as the most appropriate method. - Decided against assessee.
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