https://www.taxtmi.com/caselaws?id=445398 Where an Indian enterprise merely resells goods acquired from associated enterprises without meaningful value addition, the appropriate transfer pricing prescription is to apply the Resale Price Method (RPM) rather than the Transactional Net Margin Method (TNMM); the determinative benchmark is the gross margin on resale after cost of sale, and absence of comparables supporting TNMM justifies its rejection, yielding the operative effect that the Tribunal's choice of RPM was correct and the legal question resolved against the revenue and in favour of the assessee. en-us Thu, 12 Oct 2023 00:00:00 +0530 Wed, 18 Feb 2026 16:00:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445398 Where an Indian enterprise merely resells goods acquired from associated enterprises without meaningful value addition, the appropriate transfer pricing prescription is to apply the Resale Price Method (RPM) rather than the Transactional Net Margin Method (TNMM); the determinative benchmark is the gross margin on resale after cost of sale, and absence of comparables supporting TNMM justifies its rejection, yielding the operative effect that the Tribunal's choice of RPM was correct and the legal question resolved against the revenue and in favour of the assessee. Case-Laws Income Tax Thu, 12 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445398