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    <title>2016 (1) TMI 1381 - ITAT DELHI</title>
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    <description>The Tribunal found that the assessee was predominantly a distributor rather than a manufacturer, upholding the Resale Price Method (RPM) as the Most Appropriate Method (MAM) for the distribution segment. Internal comparables were preferred over external ones, and adjustments for statutory levies were allowed while those for marine freight and insurance charges were rejected. The Tribunal directed a fresh adjudication by the Assessing Officer/TPO, using RPM and internal comparables for determining the Arm&#039;s Length Price (ALP). The appeals were allowed for statistical purposes, with the order pronounced on 07.01.2016.</description>
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    <pubDate>Thu, 07 Jan 2016 00:00:00 +0530</pubDate>
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      <title>2016 (1) TMI 1381 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=274869</link>
      <description>The Tribunal found that the assessee was predominantly a distributor rather than a manufacturer, upholding the Resale Price Method (RPM) as the Most Appropriate Method (MAM) for the distribution segment. Internal comparables were preferred over external ones, and adjustments for statutory levies were allowed while those for marine freight and insurance charges were rejected. The Tribunal directed a fresh adjudication by the Assessing Officer/TPO, using RPM and internal comparables for determining the Arm&#039;s Length Price (ALP). The appeals were allowed for statistical purposes, with the order pronounced on 07.01.2016.</description>
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