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Transfer pricing adjustment - Purchase of goods from Associated Enterprises (AE) - Most Appropriate Method (MAM) - Resale Price Method (RPM) considered as MAM for assessee engaged in buy-sell model and sales commission model without value addition. Comparable selection - ECMAS Resins Private Limited (manufacturer) rejected; trading filter range of 30%-40% accepted. Arrow Technical Textile Private Limited excluded due to dissimilar products. Working capital adjustment claim remitted for reconsideration. RPM upheld as MAM based on assessee's functional profile. Appeal partly allowed.
Transfer pricing adjustment - Purchase of goods from Associated Enterprises (AE) - Most Appropriate Method (MAM) - Resale Price Method (RPM) considered as MAM for assessee engaged in buy-sell model and sales commission model without value addition. Comparable selection - ECMAS Resins Private Limited (manufacturer) rejected; trading filter range of 30%-40% accepted. Arrow Technical Textile Private Limited excluded due to dissimilar products. Working capital adjustment claim remitted for reconsideration. RPM upheld as MAM based on assessee's functional profile. Appeal partly allowed.
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