https://www.taxtmi.com/caselaws?id=783197 ITAT Delhi held that the assessee, engaged in fashion retail as a routine distributor of finished goods imported from its AE without any value addition, is the appropriate tested party for transfer pricing analysis. Classifying the AE as the principal assuming core entrepreneurial and business risks, the Tribunal ruled that Resale Price Method (RPM), not Transactional Net Margin Method (TNMM), is the most appropriate method for benchmarking the international transaction of import of finished goods. The assessee's gross profit/sales margin under RPM was accepted as correctly determining the arm's length price, and the TP adjustment was deleted. en-us Mon, 08 Dec 2025 00:00:00 +0530 Thu, 11 Dec 2025 08:55:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783197 ITAT Delhi held that the assessee, engaged in fashion retail as a routine distributor of finished goods imported from its AE without any value addition, is the appropriate tested party for transfer pricing analysis. Classifying the AE as the principal assuming core entrepreneurial and business risks, the Tribunal ruled that Resale Price Method (RPM), not Transactional Net Margin Method (TNMM), is the most appropriate method for benchmarking the international transaction of import of finished goods. The assessee's gross profit/sales margin under RPM was accepted as correctly determining the arm's length price, and the TP adjustment was deleted. Case-Laws Income Tax Mon, 08 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783197