https://www.taxtmi.com/caselaws?id=345806 For transfer pricing benchmarking of imported raw materials, components and semi-finished goods in the manufacturing segment, the Court held that CUP could not be applied because the ITAT proceeded on a mistaken factual premise that the CIT(A) had upheld CUP, while the CIT(A) had in fact accepted TNMM; that finding was set aside. For imported finished goods in the trading segment, the Court similarly held that RPM could not be sustained because the ITAT wrongly assumed CIT(A) had approved RPM, and there was no material change in the assessee's business profile or transactions across years; that finding was also set aside. The CIT(A)'s order was affirmed and the Revenue's challenge failed. en-us Tue, 11 Jul 2017 00:00:00 +0530 Sat, 25 Oct 2025 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345806 For transfer pricing benchmarking of imported raw materials, components and semi-finished goods in the manufacturing segment, the Court held that CUP could not be applied because the ITAT proceeded on a mistaken factual premise that the CIT(A) had upheld CUP, while the CIT(A) had in fact accepted TNMM; that finding was set aside. For imported finished goods in the trading segment, the Court similarly held that RPM could not be sustained because the ITAT wrongly assumed CIT(A) had approved RPM, and there was no material change in the assessee's business profile or transactions across years; that finding was also set aside. The CIT(A)'s order was affirmed and the Revenue's challenge failed. Case-Laws Income Tax Tue, 11 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345806