https://www.taxtmi.com/caselaws?id=314560 The ITAT Jaipur ruled in favor of the assessee regarding transfer pricing adjustment disputes. The TPO had rejected the assessee's use of Gross Profit Margin/Cost of Production as PLI and instead applied Operating Profit/Value Added Expenses (Berry Ratio) for benchmarking international transactions. The ITAT held that given the assessee's manufacturing profile, functions performed, assets employed, and risks undertaken in manufacturing and exporting colored stones and studded jewelry, the Cost Plus Method with GP/COP was the appropriate PLI. The tribunal found the assessee's transactions met arm's length requirements and directed deletion of the transfer pricing adjustment. en-us Mon, 07 Feb 2022 00:00:00 +0530 Thu, 20 Jun 2024 06:55:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314560 The ITAT Jaipur ruled in favor of the assessee regarding transfer pricing adjustment disputes. The TPO had rejected the assessee's use of Gross Profit Margin/Cost of Production as PLI and instead applied Operating Profit/Value Added Expenses (Berry Ratio) for benchmarking international transactions. The ITAT held that given the assessee's manufacturing profile, functions performed, assets employed, and risks undertaken in manufacturing and exporting colored stones and studded jewelry, the Cost Plus Method with GP/COP was the appropriate PLI. The tribunal found the assessee's transactions met arm's length requirements and directed deletion of the transfer pricing adjustment. Case-Laws Income Tax Mon, 07 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314560