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2022 (12) TMI 1072 - ITAT DELHITP Adjustment - selection of MSM - RPM or TNMM - Transaction pertaining to purchase of goods for the purpose of resale in India - TPO objected to the arm’s length margin computed in relation to trading segment, by rejecting RPM adopted by the assessee for the trading segment and applied Transactional Net Margin Method (‘TNMM’) to benchmark the trading segment - HELD THAT:- We have no hesitation to hold that the assessee is a pure trading company involved in the distribution activity without adding any value to the purchased product and hence the RPM is the most appropriate method. We, accordingly, direct the Assessing Officer/TPO to accept RPM as the most appropriate method and decide the issue accordingly. Since we have held that RPM is the most appropriate method, on the facts of the case in hand, all the other issues raised by the assessee will be decided accordingly.
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