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The HC ruled in favor of the assessee, confirming that RPM was the most appropriate method for benchmarking international transactions. The Court determined that the assessee functioned as a distributor, not a manufacturer, importing solar products from its AE for resale without value addition. The HC rejected revenue's contention that warranty cost claims and expense reimbursements should be aggregated with purchase transactions, finding these were separate, unrelated transactions. The Court noted that warranty costs were merely reimbursed by the AE without any service element. Following precedents in Burberry India, Matrix Cellular, and Fujitsu India, the HC held that RPM is appropriate for distributors without product value addition, and that transaction aggregation is fact-dependent rather than a question of law.
The HC ruled in favor of the assessee, confirming that RPM was the most appropriate method for benchmarking international transactions. The Court determined that the assessee functioned as a distributor, not a manufacturer, importing solar products from its AE for resale without value addition. The HC rejected revenue's contention that warranty cost claims and expense reimbursements should be aggregated with purchase transactions, finding these were separate, unrelated transactions. The Court noted that warranty costs were merely reimbursed by the AE without any service element. Following precedents in Burberry India, Matrix Cellular, and Fujitsu India, the HC held that RPM is appropriate for distributors without product value addition, and that transaction aggregation is fact-dependent rather than a question of law.
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