2020 (12) TMI 1366

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.... G. Guruswamy, CIT (D.R). ORDER PER SHRI CHANDRA POOJARI, A.M. : This appeal filed by the assessee is directed against the order of Assessing Officer dt.03.09.2018 for the Assessment Year 2014-15 passed u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 ('the Act'). 2. The assessee has raised various grounds with regard to Transfer Pricing. However, the grounds relating to Transfer....

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....d acceptance. In view of the above submissions of the A.R., we are inclined to allow withdrawal of TP grounds in relation to US entities and dismiss these grounds as withdrawn. 3. Further the assessee filed additional grounds as follows : " That the learned Transfer Pricing Officer, the ld. DCIT, Circle 7(1)(1), Bangalore and the Dispute Resolution Panel has erred on rejecting Resale Price Meth....

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....tional ground. 5. We have heard both the parties on admission of the additional ground. In view of the judgement of the Hon'ble Supreme Court in the case of NTPC Ltd. Vs. CIT 229 ITR 383 (SC), we are inclined to admit the additional ground for adjudication. 6. The facts relating to this additional ground are that the in the distribution segment, the assessee has taken Resale Price Method (RP....

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....f putting 20-30 components. Accordingly, the TPO rejected RPM method to determine the Arm's Length Price (ALP) and followed TNMM method. Now the contention of the ld. AR is that the RPM method is most suitable method to determine the ALP of the transaction. He submitted that he could give segmental details of the traded goods and in respect of traded goods RPM method is being applied. On the other....