https://www.taxtmi.com/caselaws?id=327007 The Tribunal held that the transfer pricing analysis could not be rejected by benchmarking the assessee against a group company's operating margin without regard to its functional, asset and risk profile. As the assessee was only a distributor in the initial period of operations, with no value addition, warehousing or R&D, the resale price method supported by comparable margins was accepted as the more appropriate benchmark. Profit attribution to India based on assumptions and arbitrary apportionment between India and abroad was found unsustainable, and the assessee's transfer pricing study was accepted. en-us Mon, 21 Mar 2016 00:00:00 +0530 Sat, 30 Apr 2016 11:22:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327007 The Tribunal held that the transfer pricing analysis could not be rejected by benchmarking the assessee against a group company's operating margin without regard to its functional, asset and risk profile. As the assessee was only a distributor in the initial period of operations, with no value addition, warehousing or R&D, the resale price method supported by comparable margins was accepted as the more appropriate benchmark. Profit attribution to India based on assumptions and arbitrary apportionment between India and abroad was found unsustainable, and the assessee's transfer pricing study was accepted. Case-Laws Income Tax Mon, 21 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327007