https://www.taxtmi.com/caselaws?id=780200 ITAT (DELHI - AT) held RPM to be the MAM for the distribution segment where the taxpayer purchased traded goods from AEs on a principal-to-principal basis with no value addition. Consistency with prior years where RPM was accepted warranted similar treatment for the year under review; the taxpayer's margins were found within the ALP range and accepted. Transfer-pricing adjustments were deleted insofar as a 15% markup had already been charged on certain recoveries, no markup was warranted on AE-funded price/project support and replacement costs, and alleged under-reporting of support income was not sustained. Relevant grounds were partly allowed and AO/TPO directed to delete the adjustments. en-us Wed, 08 Oct 2025 00:00:00 +0530 Sat, 25 Oct 2025 09:00:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780200 ITAT (DELHI - AT) held RPM to be the MAM for the distribution segment where the taxpayer purchased traded goods from AEs on a principal-to-principal basis with no value addition. Consistency with prior years where RPM was accepted warranted similar treatment for the year under review; the taxpayer's margins were found within the ALP range and accepted. Transfer-pricing adjustments were deleted insofar as a 15% markup had already been charged on certain recoveries, no markup was warranted on AE-funded price/project support and replacement costs, and alleged under-reporting of support income was not sustained. Relevant grounds were partly allowed and AO/TPO directed to delete the adjustments. Case-Laws Income Tax Wed, 08 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780200