https://www.taxtmi.com/caselaws?id=259976 In a job-work transfer pricing context, gold supplied free of cost by an associated enterprise was treated as a pass-through item, so its value could not be added to operating cost; the assessee was regarded as a job worker rather than a manufacturer. On the pricing method, the Tribunal accepted external comparable uncontrolled transactions for making charges in similar job-work arrangements and held that TNMM was unsuitable where a direct method was workable, so the CUP-based approach prevailed. Freight and insurance reimbursements supported by documentary evidence were treated as mere reimbursements and not income for transfer pricing adjustment, resulting in deletion of the additions. en-us Mon, 18 May 2015 00:00:00 +0530 Wed, 31 Dec 2025 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259976 In a job-work transfer pricing context, gold supplied free of cost by an associated enterprise was treated as a pass-through item, so its value could not be added to operating cost; the assessee was regarded as a job worker rather than a manufacturer. On the pricing method, the Tribunal accepted external comparable uncontrolled transactions for making charges in similar job-work arrangements and held that TNMM was unsuitable where a direct method was workable, so the CUP-based approach prevailed. Freight and insurance reimbursements supported by documentary evidence were treated as mere reimbursements and not income for transfer pricing adjustment, resulting in deletion of the additions. Case-Laws Income Tax Mon, 18 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259976