Tribunal's conclusion that Resale Price Method (RPM) is the most ...

Manufacturing Co's transfer pricing method upheld; AMP expenses deemed comparable.

Case Laws Income Tax

November 11, 2024

Tribunal's conclusion that Resale Price Method (RPM) is the most appropriate method upheld. Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) had rejected RPM, citing assessee's significant Advertisement, Marketing and Promotion (AMP) expenses. However, Tribunal accepted assessee's contention that AMP expenses were not excessive and comparable to other entities. DRP's finding that assessee was not a 'routine distributor' sustainable. Revenue's challenge to Tribunal's decision dismissed, no substantial question of law arises.

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Tribunal's conclusion that Resale Price Method (RPM) is the most ...

Manufacturing Co's transfer pricing method upheld; AMP expenses deemed comparable.

Case Laws Income Tax

November 11, 2024

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