https://www.taxtmi.com/caselaws?id=433890 For a trading segment involving import of finished goods from associated enterprises and resale to third parties without value addition, the Resale Price Method was treated as the appropriate transfer pricing method under Rule 10B(1)(b) where reliable segmental gross profit data was available. On those facts, substitution of the Transactional Net Margin Method was found unjustified, because the resale activity did not involve value addition that would distort gross margin benchmarking. The transfer pricing adjustment therefore could not be sustained, and the trading segment was benchmarked under the Resale Price Method. en-us Mon, 28 Nov 2022 00:00:00 +0530 Sat, 11 Feb 2023 10:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433890 For a trading segment involving import of finished goods from associated enterprises and resale to third parties without value addition, the Resale Price Method was treated as the appropriate transfer pricing method under Rule 10B(1)(b) where reliable segmental gross profit data was available. On those facts, substitution of the Transactional Net Margin Method was found unjustified, because the resale activity did not involve value addition that would distort gross margin benchmarking. The transfer pricing adjustment therefore could not be sustained, and the trading segment was benchmarked under the Resale Price Method. Case-Laws Income Tax Mon, 28 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433890