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    <title>2018 (5) TMI 1374 - ITAT PUNE</title>
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    <description>In DRP proceedings, additional evidence relevant to transfer pricing objections must be considered where the statute and rules permit it, and late filing alone is not a valid ground for rejection; the raw-material issue was therefore remitted for fresh adjudication. For import of finished goods resold without value addition, the Resale Price Method was held to be the appropriate benchmark, and the adjustment was deleted subject to verification of margins. For export of reusable packing material, no transfer pricing adjustment was warranted on the facts, and the addition was deleted. The overall effect was relief to the assessee on the substantive transfer pricing disputes, with only the raw-material issue restored to the DRP.</description>
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      <title>2018 (5) TMI 1374 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=360810</link>
      <description>In DRP proceedings, additional evidence relevant to transfer pricing objections must be considered where the statute and rules permit it, and late filing alone is not a valid ground for rejection; the raw-material issue was therefore remitted for fresh adjudication. For import of finished goods resold without value addition, the Resale Price Method was held to be the appropriate benchmark, and the adjustment was deleted subject to verification of margins. For export of reusable packing material, no transfer pricing adjustment was warranted on the facts, and the addition was deleted. The overall effect was relief to the assessee on the substantive transfer pricing disputes, with only the raw-material issue restored to the DRP.</description>
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