“resale price method”

Carrier Midea India Pvt. Ltd., Gurgaon vs. DCIT, Circle- 2(1), Gurgaon

Bench: Shri R.K. Panda & Shri Kuldip Singh

taxpayer in its Transfer Pricing study in order to benchmark its international transactions qua manufacturing 3 ITA No.7675/Del./2017 segment rejected Resale Price Method (RPM) and applied “other method” by considering gross margin of comparable companies with gross margin earned by it (taxpayer). Needless to say that the international transaction

ACIT, New Delhi vs. M/S. Hermes India Retails & Distributors Pvt. Ltd., New Delhi

The appeal of the Revenue is allowed partly for statistical purpose

Bench: Shri Amit Shukla & Shri O.P. Kant[Through Video Conferencing]

expenses paid 5.2 In support of claim that transaction of purchase of traded goods is at arms’ length, the assessee chose Resale Price method (RPM) as the most appropriate method and taking the assessee as tested party, compared gross profit margin (45.11%) of the assessee with the average margin comparables

Roxtec India Private Limited, New Delhi vs. ACIT, Circle- 21(2), New Delhi

In the result, the appeal of the assessee is allowed in part and for statistical purposes

Bench: Shri Anil Chaturvedi & Shri K. Narasimha Charyassessment Year: 2013-14

with its associates. In the present case before us the issue is whether the assessee is a distributor or a manufacturer and whether resale price method is applicable to the international transactions entered into by the assessee. It is not the case that assessee has resold the same goods with ... order of the learned assessing officer/transfer pricing officer as well as the direction of the learned dispute resolution panel in rejecting the resale price method adopted by the assessee and adopting transactional net margin method as the most appropriate method. 13. It not the case of the Ld. AR that

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri R.K. Panda & Ms Suchitra Kamble

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH : I-2 : NEW DELHI BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND MS

M/S Bergen Engines India Pvt. Ltd., New Delhi vs. ACIT, New Delhi

Appeal of the assessee is partly allowed for statistical purpose

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing) Bergen Engines India Pvt. Ltd. Vs Acit 2Nd Floor, 52-B, Okhla Circle-4(2) Industrial Estate, New Delhi Phase-3, Okhla New Delhi Aaecb7223M (Appellant) (Respondent)

well as the DRP and consequently the AO have grossly erred in law and on fact of the assessee’s case in rejecting Resale Price Method (RPM) applied by the assessee as most appropriate method (MAM) for benchmarking the transaction of purchase of traded goods, on erroneous facts and reasons ... there no value addition done through further processing or 9 manufacturing. This factual aspect was not at all disputed by the TPO. The resale price method is to be adopted only when goods purchased from an AE are resold to unrelated parties and therefore, the present assessee must have taken

CIT vs. Cushman and Wakefield India Pvt Ltd

The appeal is partly allowed

functions performed by such persons or such other relevant factors as the Board may prescribe, namely: (a) Comparable uncontrolled price method; (b) Resale price method; (c) Cost plus method; (d) Profit split method; (e) Transactional net margin method; (f) Such other method as may be prescribed by the Board. Section