Transfer Pricing Adjustment on Asset Purchase Upheld; 5% Markup Justified for Admin and Freight Costs; TPO Addition Deleted.

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....TP Adjustment - Mark up on purchase of fixed assets - assessee has filed the reasons for charging 5% as markup that is for taking care of administration and fright cost. It is not submitted before us any document relating to prices i.e. whether it is FOB or C & IF prices. Since the AE has supplied the assets on cost to cost with a markup of 5% and the Customs has accepted the transaction as reasonable we do not see any reason to disturb the transaction. - addition made by the TPO deleted - AT....