Tax Authorities Err in Transfer Pricing Adjustment, Misapply Resale Price Method in Import Transactions of Associated Enterprises.

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....TP Adjustment - RPM - assessee and the comparables have used Indian GAAP - the selling and marketing expenses - TPO/DRP while dislodging the RPM had lost sight of the fact that only the transaction of import of goods by the assessee from its AEs were to be benchmarked and all the other functions carried out by the assessee having no nexus with the said import transactions were, thus, not relevant for the said benchmarking analysis....