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2023 (11) TMI 289 - HC - Income TaxTP Adjustment - MAM selection - RPM v/s TNMM - Tribunal rejecting the Transactional Net Margin Method (TNMM) as used by TPO in ascertaining ALP - As per assessee it should be Resale Price Method (RPM) as it is a distributor which did not make any value addition to the goods received by it from its principal - HELD THAT:- Having regard to the findings of fact returned by the Tribunal and the principle of law enunciated by the coordinate bench of this court in Matrix Cellular International Services (P.) Ltd [2017 (11) TMI 1655 - DELHI HIGH COURT] held that once the ITAT, on considering the relevant facts as well as the order of the TPO, had concluded that the business of the assessee was merely that of a pure trader, and there was no value addition made before re-selling the particular products (i.e. the SIM cards), its consequent finding that RPM is the Most Appropriate Method, is irreproachable. Decided in favour of the assessee.
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