https://www.taxtmi.com/caselaws?id=775222 ITAT DELHI ruled in favor of the assessee regarding transfer pricing adjustments in distribution operations. The tribunal held that the assessee, functioning as a low-risk distributor providing only logistics and administrative services without inventory maintenance or value addition, correctly applied Berry ratio as the profit level indicator under TNMM instead of the net cost plus margin method adopted by TPO. The tribunal found the assessee's approach reasonable since it excluded cost of goods from the denominator, similar to comparable companies. Consequently, transfer pricing adjustments for both distribution and manufacturing segments were deleted. Regarding interest under section 234A, the tribunal directed AO to verify if the return was filed within the extended deadline per CBDT Circular 1/2022, potentially exempting the assessee from delay-related interest charges. en-us Fri, 18 Jul 2025 00:00:00 +0530 Tue, 22 Jul 2025 08:25:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775222 ITAT DELHI ruled in favor of the assessee regarding transfer pricing adjustments in distribution operations. The tribunal held that the assessee, functioning as a low-risk distributor providing only logistics and administrative services without inventory maintenance or value addition, correctly applied Berry ratio as the profit level indicator under TNMM instead of the net cost plus margin method adopted by TPO. The tribunal found the assessee's approach reasonable since it excluded cost of goods from the denominator, similar to comparable companies. Consequently, transfer pricing adjustments for both distribution and manufacturing segments were deleted. Regarding interest under section 234A, the tribunal directed AO to verify if the return was filed within the extended deadline per CBDT Circular 1/2022, potentially exempting the assessee from delay-related interest charges. Case-Laws Income Tax Fri, 18 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775222