Transfer Pricing Dispute: RPM Deemed Most Appropriate Method for Benchmarking Complex International Trading Transactions

In a transfer pricing dispute, the ITAT addressed the appropriateness of the Resale Price Method (RPM) versus the Transactional Net Margin Method (TNMM). The tribunal found that the assessee's transactions involving purchase and sales were interconnected, rendering RPM the most appropriate method for benchmarking. The Dispute Resolution Panel's general observations were deemed insufficient, and the Transfer Pricing Officer was directed to reconsider the method. The tribunal concluded that the RPM method was justified for trading transactions, and the TNMM approach was not tenable given the complex nature of the assessee's international transactions. .....

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