https://www.taxtmi.com/caselaws?id=790697 Under the Resale Price Method, import duty borne on imported traded goods must be excluded from operating cost where the duty materially affects comparability with uncontrolled comparables having negligible import content, because Rule 10B requires reasonably accurate adjustments for material differences affecting gross profit margins. Working capital differences are also a recognised comparability factor; where the assessee furnishes the necessary data, the adjustment should be considered in determining the arm's length price. On these principles, relief was granted on both import duty and working capital adjustment, resulting in partial allowance of the transfer pricing claim. en-us Wed, 25 Mar 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790697 Under the Resale Price Method, import duty borne on imported traded goods must be excluded from operating cost where the duty materially affects comparability with uncontrolled comparables having negligible import content, because Rule 10B requires reasonably accurate adjustments for material differences affecting gross profit margins. Working capital differences are also a recognised comparability factor; where the assessee furnishes the necessary data, the adjustment should be considered in determining the arm's length price. On these principles, relief was granted on both import duty and working capital adjustment, resulting in partial allowance of the transfer pricing claim. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790697