TaxTMI 
TaxTMI 
2024 (7) TMI 1054
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.... has raised the following issues:- 1. Hon'ble Dispute Resolution Panel ("DRP") and consequently the learned Assessing Officer (""AO") erred in facts and in law in confirming the addition of Rs. 8,83,76, 149/- on account of variation in Arm's Length Price (*"ALP") of the transaction of purchase of goods from Associated Enterprises ("AE"). 2. Hon'ble DRP and consequently the learned AO erred in facts and in law in rejecting Transaction Net Margin Method ("TNMM") as most appropriate method for determination of ALP of the transaction of purchase of goods from AE. 3. Hon'ble DRP and consequently the learned AO erred in facts and in law in adopting Resale Price Method ("RPM") as most appropriate method f....
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.... 10. The Appellant craves leave to add, alter and amend any of the grounds of appeal prior to or at the time of hearing of the appeal." 3. Representatives of both the sides were heard at length. Case records carefully perused and the judicial decisions brought to our notice duly considered. 4. Briefly stated, the facts of the case are that the primary business of the assessee during the year under consideration is to sell and distribute fiber glass products which are manufactured by its overseas AEs. The assessee adopted both the buy-sell model as well as sales commission model depending on how the customers are acquired and maintained. 5. In the buy-sell model, assessee imports products from its overseas AEs and resells the same ....
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....jiang Co. Ltd. Rs. 3,40,145 8 Issue of Shares China Jushi Co. Ltd. Rs. 35,03,860 9 Issue of Shares Jushi Group Hong Kong Co. Ltd. Rs. 35,390 10 Reimbursement of expenses Jushi Group Co. Ltd. Rs. 9,99,999 Total Rs. 121,57,34,619 8. During the course of scrutiny assessment proceedings, the Transfer Pricing Officer (TPO) showcaused the assessee to explain as to why Transactional Net Margin Method (TNMM), should not be rejected and RPM applied as MAM. The assessee in its reply, strongly rejected the RPM as the MAM contending absence of reliable data with respect to degree of comparability and absence of reliance date relating to gross margins earned by the comparable companies.....
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....Nations with a sustainable ecological environment commitment. Moreover, this company has a wide range of product mix which primarily deals in textile fiber and carbon fiber and fabrics and this company is offering composite fibers such as High Silica, Carbon Fiber, Basalt Fiber, Aramid, EMI (electromagnetic induction) and ESD (electromagnetic sensitive devices). The principle business activity of the company is trading in textile products. 10.1. In our considered opinion, this is entirely different from the products sole by the assessee. The assessee deals in basic glass fiber products like assemble rovings, direct rovings, chopped strands, shopper strand mat. Thus, the products offered by ATTPL are quite different from fiber glass produ....