ITAT upheld the assessee's adoption of the resale price method...

ITAT upheld the assessee's adoption of the resale price method (RPM) as the most appropriate method for the distribution segment, finding RPM preferable to TNMM because the assessee purchased traded goods from associated enterprises on a principal-to-principal basis without value addition; accordingly the assessee's margins were accepted as at arm's length. The Tribunal allowed relief on mark-up adjustments where payments recovered from AEs (price support, project/advertising support, replacement costs and specified service recoveries) were evidenced as cost-to-cost reimbursements or already bore a contractual mark-up, directing deletion of corresponding TP adjustments and finding no under-reporting in statutory TP returns; certain grounds were partly allowed on consistency and FAR analysis.

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