https://www.taxtmi.com/caselaws?id=763413 In transfer pricing adjustment, the relevant comparison method turned on the assessee's functional profile: where the ITAT found it to be a pure trader with no value addition before resale of SIM cards, it treated the Resale Price Method as the Most Appropriate Method and rejected the Transactional Net Margin Method used by the TPO for ALP determination. The Supreme Court noted an unexplained delay of 311 days in filing the SLP and also found no merit in the challenge, so the SLP was dismissed on delay as well as on merits. en-us Mon, 16 Dec 2024 00:00:00 +0530 Wed, 29 Apr 2026 14:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763413 In transfer pricing adjustment, the relevant comparison method turned on the assessee's functional profile: where the ITAT found it to be a pure trader with no value addition before resale of SIM cards, it treated the Resale Price Method as the Most Appropriate Method and rejected the Transactional Net Margin Method used by the TPO for ALP determination. The Supreme Court noted an unexplained delay of 311 days in filing the SLP and also found no merit in the challenge, so the SLP was dismissed on delay as well as on merits. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763413