Transfer Pricing Adjustment: AO/TPO Must Benchmark Raw Material Imports with Comparable Companies if Appellant's Analysis is Unacceptable.

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....TP Adjustment - import of raw materials from AEs - international transaction - in case the AO / TPO on examination of benchmarking analysis made by the appellant company is found to be not acceptable, the AO / TPO shall examine the relevance of comparison of gross profits of appellant company with the comparable companies and proceed to benchmark the international transaction of import of raw materials. - AT....