The Mumbai ITAT rejected the assessee's own recharacterization as value added distributor and upheld the CUP method to benchmark import of Active Pharmaceutical Ingredients. The Bench comprising Vikas Awasthy and Gagan Goyal observed that “segregation of Contract Manufacturing activity and Distribution is fair and reasonable. The TPO rejected assessee's TNMM and adopted CUP method as MAM, collecting data from Customs …
The Pune bench of the Income Tax Appellate Tribunal has held that the Transactional Net Margin Method should be applied in respect of international transactions of `Sale of finished goods’.The bench of R.S. The Pune bench of the Income Tax Appellate Tribunal has held that the Transactional Net Margin Method should be applied in respect of international transactions of `Sale …
The Bombay High Court has held that the transaction of payment of royalty for the use of technology is inextricably linked with manufacturing activity and should be aggregated with other international transactions in the manufacturing segment for the purposes of benchmarking it.The bench of Justice K.R. The Bombay High Court has held that the transaction of payment of royalty for …
The Delhi Bench of the Income Tax Appellate Tribunal consisting of Yogesh Kumar and Dr. B.R.R. Subsequently, a draft assessment order under section 143 read with section 144C of the Income Tax Act was passed, proposing Transfer Pricing Adjustment on the basis of TPO's order. An assessment order was passed under section 143 read with section 144C of the Income …
