https://www.taxtmi.com/caselaws?id=767551 Delhi HC held that ITAT correctly applied RPM as the most appropriate method for benchmarking international transactions. The assessee was a distributor, not manufacturer, importing solar products from associated enterprise for resale. Warranty cost claims were separate unrelated transactions, not inextricably linked to product purchases, thus no aggregation required. TPO and DRP erred in concluding RPM inappropriate based on flawed assumption that warranty costs and product purchases were interconnected. Court distinguished between distribution activities and value addition, finding no manufacturing or substantial value addition warranting TNMM over RPM. Revenue's appeal dismissed as no substantial question of law arose. en-us Tue, 18 Mar 2025 00:00:00 +0530 Thu, 20 Mar 2025 08:21:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767551 Delhi HC held that ITAT correctly applied RPM as the most appropriate method for benchmarking international transactions. The assessee was a distributor, not manufacturer, importing solar products from associated enterprise for resale. Warranty cost claims were separate unrelated transactions, not inextricably linked to product purchases, thus no aggregation required. TPO and DRP erred in concluding RPM inappropriate based on flawed assumption that warranty costs and product purchases were interconnected. Court distinguished between distribution activities and value addition, finding no manufacturing or substantial value addition warranting TNMM over RPM. Revenue's appeal dismissed as no substantial question of law arose. Case-Laws Income Tax Tue, 18 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767551