https://www.taxtmi.com/caselaws?id=770517 The ITAT Ahmedabad ruled in favor of the assessee regarding transfer pricing method selection. The DRP had rejected the assessee's use of Resale Price Method (RPM) for benchmarking international transactions involving both purchases and sales, arguing that various expenses incurred in India added significant value, making gross margin analysis inappropriate. However, the ITAT found the DRP's reasoning general and inadequate. The tribunal held that RPM was the most appropriate method for the trading transactions as demonstrated by the assessee, since the transactions were inter-linked and the assessee had proven arm's length pricing. The TPO was directed to reconsider and apply RPM instead of TNMM for benchmarking purposes. en-us Fri, 09 May 2025 00:00:00 +0530 Mon, 12 May 2025 09:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770517 The ITAT Ahmedabad ruled in favor of the assessee regarding transfer pricing method selection. The DRP had rejected the assessee's use of Resale Price Method (RPM) for benchmarking international transactions involving both purchases and sales, arguing that various expenses incurred in India added significant value, making gross margin analysis inappropriate. However, the ITAT found the DRP's reasoning general and inadequate. The tribunal held that RPM was the most appropriate method for the trading transactions as demonstrated by the assessee, since the transactions were inter-linked and the assessee had proven arm's length pricing. The TPO was directed to reconsider and apply RPM instead of TNMM for benchmarking purposes. Case-Laws Income Tax Fri, 09 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770517