Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
For import of finished goods by a routine distributor, RPM was treated as the most appropriate transfer pricing method because the assessee merely resold the imported products without processing, physical alteration, or value addition, and no local intangibles were shown. Advertising, sales and distribution expenditure below the gross profit line did not affect RPM analysis, so rejection of RPM in favour of TNMM was unwarranted. Interest under the relevant provisions was left to follow the assessment outcome, while the challenge to initiation of penalty proceedings was held premature.
For import of finished goods by a routine distributor, RPM was treated as the most appropriate transfer pricing method because the assessee merely resold the imported products without processing, physical alteration, or value addition, and no local intangibles were shown. Advertising, sales and distribution expenditure below the gross profit line did not affect RPM analysis, so rejection of RPM in favour of TNMM was unwarranted. Interest under the relevant provisions was left to follow the assessment outcome, while the challenge to initiation of penalty proceedings was held premature.
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