| COURT: | ITAT Delhi |
| CORAM: | George George K (JM), R. S. Syal (AM) |
| SECTION(S): | 92C, 92CA, Rule 10B |
| GENRE: | Transfer Pricing |
| CATCH WORDS: | ALP, Arms length price, Resale Price Method, Transfer Pricing |
| COUNSEL: | Atul Ninawat |
| DATE: | October 31, 2014 (Date of pronouncement) |
| DATE: | November 3, 2014 (Date of publication) |
| AY: | 2002-03 |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| (i) Method of applying Resale Price Method (RPM) method, (ii) high advertisement expenses has no bearing on the RPM, (iii) comparables with more than 25% of related party transactions (RPTs) have to be excluded, (iv) transactions which do not impact the profitability should be excluded from the formula, (v) potentially comparable companies cannot be expelled only on the ground of high or low turnover | |
(i) The assessee simply purchased mobile phones and accessories from Nokia group companies situated outside India and resold the same as such without any further value addition, mainly, to HCL Infosystems in India. Since the goods imported from the foreign …
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