“resale price method”

Tpg Growth II Makets Pte Ltd., Mumbai vs. DCIT 4(1)(2), Mumbai

Accordingly, Ground No. 4 raised by the Appellant is partly allowed

determined by applying the Most Appropriate Method out of the following six methods: (a) Comparable Uncontrolled Price Method (For short ‘CUP Method’) (b) Resale Price Method (RPM) (c) Cost Plus Method (CPM) (d) Profit Split Method (PSM) (e) Transactional Net Margin Method (TNMM) (f) Such other method

Jiostar India Private Limited, Mumbai vs. Asst CIT 16 (1), Mumbai

Bench: Shri R.S. Syal (V.P.), Shri Aby T. Varkey (J.M.) & Shri Prashant Maharishi (A.M.) आयकर अपील सं. / Ita. No.7872/Mum/2019 "नधा"रण वष" / Assessment Year : 2015-16

such other relevant factors as the Board may prescribe. Five specific methods have been set out, namely, (a) comparable uncontrolled price method; (b) resale price method; (c) cost plus method; (d) profit split method; (e) transactional net margin method. Thereafter, another method is given in clause (f), namely, such other ... adjustment on account of unutilized capacity. The Tribunal observed that the most appropriate method, in the facts of the case, was the Resale price method (RPM). It accordingly directed to apply the RPM. The Revenue, in its appeal before the Hon’ble High Court, insisted that it was not open

Deputy Commissioner of Income Tax 14(2)(1), Mumbai vs. India Debt Management Private Limited, Mumbai

appropriate rate; and  Establishing an arm's length interest rate (all-in-rate) for the credit facility based on the above searches. 4.5.2.2. Resale price method 10 xx xx 4.5.2.3. Cost plus method xx xx 4.5.2.4. Profit split method xx xx 4.5.2.5. Transactional net margin method xx xx 4.5.2.6. Other

Dy Commissioner of Income Tax -6(1)(2), Mumbai-400020 vs. M/S. Bristol Myers Squibb India P Ltd., Mumbai-400018

In the result, appeal of the Revenue is partly allowed and the assessee’s cross objections are dismissed

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Rs.43,39,27,130/- and an assessment order was passed incorporating the TP adjustment. The TPO, while making the TP adjustment, rejected the resale price method (RPM) adopted by the assessee for the 3 ITA 175/Mum/2022 M/s Bristol Myers Squibb India Pvt Ltd reason that the assessee is carrying ... hereinabove, the assessee had in its TP study report benchmarked the aforesaid transactions of purchase of formulations from its AE by adopting resale price method (RPM) as the most appropriate method. The core controversy involved in the present appeal hinges around the view taken by the lower authorities that

Abbott India Ltd (As Successor to Solvay Pharma India Ltd), Mumbai vs. Addl CIT RG 7(2), Mumbai

In the result, appeal filed by the assessee is allowed partly for statistical purposes

Bench: Shri Om Prakash Kant () & Ms Kavitha Rajagopal () Assessment Year: 2007-08 Abott India Limited Addl. Cit-Range 7(2) Unit 3-4, Corporate Park, Aayakar Bhavan, M.K. Sion-Trombay Road, Chembur, Vs. Marg, Mumbai-400 071. Mumbai-400 020 Pan No. Aaacu 9269 Q Appellant Respondent Assessee By : Shri. Madhur Agrawal, Adv. Revenue By : Shri Yogesh Kamat, Cit Dr Date Of Hearing : 22/09/2022 Date Of Pronouncement : 30/11/2022

concerned, the Rule10B, introduced by way of IT (21st amendment) Rules, 2001 has provided five methods consisting of, comparable uncontrolled Price method (CUP), Resale Price Method (RPM), Cost Plus Method (CPM), profit split method (PSM) Transactional Net Margin Method (TNMM). With effect from 01-04-2012 one more method

Torrecid India Pvt. Ltd, Mumbai vs. Income Tax Circle-3(3) (1), Mumbai

Appeal of the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Torrecid India Private Limited Income Tax Circle-3(3)(1) Flat No. 29,30,31, Gidc, Savli, Aaykar Bhavan, Mumbai-400 Alidra, Vadodara, Vs. 020 Gujarat-391775 (Appellant) (Respondent) Pan No. Aabcl4860B Assessee By : Shri. Sagar Sawhney. Revenue By : Shri. Samuel Pitta Srar Date Of Hearing: 01.09.2022 Date Of Pronouncement : 28.11.2022

length price of international transaction of import of finished goods rejecting the most appropriate method adopted by the assessee of resale price method, but the transactional net margin method adopted by the TPO. Torrecid India Private Limited.; A.Y.2017-18 02. The assessee has raised following grounds of appeal: “Based ... erred in and the Hon'ble DRP further erred in upholding / confirming the action of the TPO in unjust/erroneous rejection of Resale Price Method (RPM) considered by the Appellant in its Transfer Pricing Study Report for benchmarking the international transaction of import of finished goods for distribution without providing

Brinks India P.Ltd (Formerly Known As Brinks Arya (India ) Private Limited, Mumbai vs. DCIT Central Cir 6(4), Mumbai

In the result, the present appeal preferred by the Assessee is allowed

contemplates that the arms length price in relation to an international transaction shall be determined by comparable uncontrolled price method; resale price method; cost plus method; profit split method; transactional net margin method or such other method as may be prescribed by the Board. Hence, the TPO is bound

M/S. India Medtronics Pvt.Ltd., Baroda vs. The Dy.CIT., Circle-1(2), Baroda

In the result, similarly the Assessee’s appeal is partly allowed

Bench: Shri Amit Shukla & Shri Gagan Goyal

maintained by the Appellant as per rule 10D (1) of the Income-tax Rules, 1962”. 5. “the learned AO/ TPO erred in selecting Resale Price Method (‘RPM’) as the most appropriate method and in rejecting the Transactional Net Margin Method (‘TNMM’) selected by the appellant”. 6. “the learned ... transaction. Having done so, the Transfer Pricing Officer held that since the Assessee is engaged in the activity of marketing and distribution, Resale Price Method (RPM) would be the most appropriate method to benchmark the import of finished goods. Further, the Transfer Pricing Officer applied RPM by considering Medtronic Malaysia

DCIT 14(3)(1), Mumbai vs. Komli Wedia India P.Ltd, Mumbai

In the result, ITA No.3889/Mum/2017 for A

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Ld.CIT (A) erred in holding that the ITA Nos.3890 & 3889/Mum/2017 Komli Wedia India P. Ltd; AYs 11-12 & 12-13 Resale Price Method (RPM) was the most appropriate method for determining the arm's length price of the assessee's international transaction in respect of purchase and sale of online ... facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in holding that the Resale Price Method (RPM) was the most appropriate method for determining the arm's length price of the assessee's international transaction in respect of purchase and sale of online