2016 (3) TMI 1393

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... E )? - HELD THAT:- The Court finds that the ITAT has, in the impugned order, held that even if the ALP is determined by applying the Transactional Net Margin Method ( TNMM ), the gross profit margin earned by the Assessee in respect of export of motorcycles to its AE is 15.83% as compared to 10.75% in respect of export of motorcycles to unrelated parties. It was also seen that the export price rea .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... e is whether the ITAT was correct in accepting the Assessee s contention regarding the application of the resale price method ( RPM ) for determining the arm s length price ( ALP ) of the international transaction entered into by the Assessee with its associated enterprise ( AE ). 3. The contention is that in terms of Rule 10 B (1)(b)(i) of the Income Tax Rules 1962, the RPM can be applied if p .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X