https://www.taxtmi.com/caselaws?id=468291 Raw kits supplied by the associated enterprise for assembly and re-export were treated as pass-through material costs, so they were excluded from the assessee's Cost Plus Method cost base because the assessee earned profit only on value-addition services. Astra Microwave Component Ltd. was held not to be functionally comparable since it operated as a full-fledged manufacturing and marketing company, unlike a captive unit performing limited processing for the same enterprise. With the retained comparable rejected, no reliable arm's length benchmark remained; the transfer pricing adjustment was therefore set aside and the matter remitted for fresh arm's length price determination under the appropriate method. en-us Wed, 15 Feb 2017 00:00:00 +0530 Mon, 27 Apr 2026 12:48:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468291 Raw kits supplied by the associated enterprise for assembly and re-export were treated as pass-through material costs, so they were excluded from the assessee's Cost Plus Method cost base because the assessee earned profit only on value-addition services. Astra Microwave Component Ltd. was held not to be functionally comparable since it operated as a full-fledged manufacturing and marketing company, unlike a captive unit performing limited processing for the same enterprise. With the retained comparable rejected, no reliable arm's length benchmark remained; the transfer pricing adjustment was therefore set aside and the matter remitted for fresh arm's length price determination under the appropriate method. Case-Laws Income Tax Wed, 15 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468291