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Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational risk assumption.
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Transactional Net Margin Method was treated as the most appropriate method for benchmarking purchases by a medical-equipment distributor performing substantial post-import functions, including configuration, integration, installation, training, warranty and maintenance support. The Resale Price Method was considered unsuitable where resale involved significant value addition and risk assumption, and the transfer-pricing adjustment based on that method was deleted. Comparable companies require verification where related-party transactions may exceed the prescribed filter. Verification was also directed to prevent double taxation where a sundry balance written back had already been offered to tax and was again added during return processing. The appeal was partly allowed, with the remaining issues remanded for fresh determination.
Transactional Net Margin Method was treated as the most appropriate method for benchmarking purchases by a medical-equipment distributor performing substantial post-import functions, including configuration, integration, installation, training, warranty and maintenance support. The Resale Price Method was considered unsuitable where resale involved significant value addition and risk assumption, and the transfer-pricing adjustment based on that method was deleted. Comparable companies require verification where related-party transactions may exceed the prescribed filter. Verification was also directed to prevent double taxation where a sundry balance written back had already been offered to tax and was again added during return processing. The appeal was partly allowed, with the remaining issues remanded for fresh determination.
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