The assessee is engaged in trading of beauty products. The TPO rejected the Transactional Net Margin Method (TNMM) and adopted Resale Price Method and rejected all comparables and selected only single comparable namely Modicare Ltd. Adjustment made by the was up held by the DRP. On appeal the Tribunal directed the TPO to apply TNMM on the comparable selected by the assessee with suitable working capital adjustment. (AY. 2013-14)
Oriflame India Pvt. Ltd. v. Add.CIT (2020) 82 ITR 268 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method (TNMM)-Held to be appropriate method-Remanded TPO to apply TNMM method. [S. 92]