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    <title>2022 (5) TMI 1001 - ITAT PUNE</title>
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    <description>The Tribunal upheld the application of Internal Resale Price Method (RPM) for the Trading segment, citing Delhi High Court&#039;s ruling. Electronica Machine Tools Ltd. was included as a comparable for the Manufacturing segment despite losses in the relevant year, following Bombay High Court precedents. The adjustment for higher Customs duty was rejected, and project expenses were deemed operating costs. Consultancy charges exclusion was remanded for further examination. The Tribunal partly allowed the Revenue&#039;s appeal and the assessee&#039;s Cross Objection. Judgment was issued on 28th April 2022.</description>
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      <link>https://www.taxtmi.com/caselaws?id=422741</link>
      <description>The Tribunal upheld the application of Internal Resale Price Method (RPM) for the Trading segment, citing Delhi High Court&#039;s ruling. Electronica Machine Tools Ltd. was included as a comparable for the Manufacturing segment despite losses in the relevant year, following Bombay High Court precedents. The adjustment for higher Customs duty was rejected, and project expenses were deemed operating costs. Consultancy charges exclusion was remanded for further examination. The Tribunal partly allowed the Revenue&#039;s appeal and the assessee&#039;s Cross Objection. Judgment was issued on 28th April 2022.</description>
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