Discrepancy in Arm's Length Price: Assessee's Custom Duty Exceeds EU Rate, Impacting Cost Analysis Significantly.

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....Addition on account of difference in Arm’s Length Price - As far as rate of custom duty is concerned, it can be easily taken from the official website of the European Union and we find that the rate at the relevant point of time was 4.5% whereas the custom duty paid by the assessee accounts for more than 75% of the purchase value and 50% of the total cost of goods sold. In our considered opinion, such difference on account of custom duty paid by the assessee and that existing in the location where comparable companies operate, cannot be ignored. - AT....