Transfer Pricing Case: RPM Upheld as Most Appropriate Method; Comparable Companies Rejected; Appeal Partly Allowed.

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....Transfer pricing adjustment - Purchase of goods from Associated Enterprises (AE) - Most Appropriate Method (MAM) - Resale Price Method (RPM) considered as MAM for assessee engaged in buy-sell model and sales commission model without value addition. Comparable selection - ECMAS Resins Private Limited (manufacturer) rejected; trading filter range of 30%-40% accepted. Arrow Technical Textile Private Limited excluded due to dissimilar products. Working capital adjustment claim remitted for reconsideration. RPM upheld as MAM based on assessee's functional profile. Appeal partly allowed.....