Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational risk assumption.

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....Transactional Net Margin Method was treated as the most appropriate method for benchmarking purchases by a medical-equipment distributor performing substantial post-import functions, including configuration, integration, installation, training, warranty and maintenance support. The Resale Price Method was considered unsuitable where resale involved significant value addition and risk assumption, and the transfer-pricing adjustment based on that method was deleted. Comparable companies require verification where related-party transactions may exceed the prescribed filter. Verification was also directed to prevent double taxation where a sundry balance written back had already been offered to tax and was again added during return processing. The appeal was partly allowed, with the remaining issues remanded for fresh determination.....