2016 (3) TMI 1393

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..... ce ( ALP ) of the international transaction entered into by the Assessee with its associated enterprise ( AE )? - HELD THAT:- The Court finds that the ITAT has, in the impugned order, held that even if the ALP is determined by applying the Transactional Net Margin Method ( TNMM ), the gross profit margin earned by the Assessee in respect of export of motorcycles to its AE is 15.83% as compared to .....

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..... n sought to be urged by the Revenue is whether the ITAT was correct in accepting the Assessee's contention regarding the application of the resale price method ('RPM') for determining the arm's length price ('ALP') of the international transaction entered into by the Assessee with its associated enterprise ('AE'). 3. The contention is that in terms of Rule 10 B (1)(b)(i) of the Income Tax Rules 1 .....

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