Held that resale of goods imported from AE to third party Indian customers without any value addition, in such case, Resale Price Method (RPM) would be Most Appropriate Method (MAM) to determine ALP of said transaction. Directed the Assessing Officer to apply Resale Price Method (RPM). (AY. 2015-16)
Randox Laboratories India (P.) Ltd. v. ACIT (2022) 193 ITD 609 / 94 ITR 163 (Bang.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Resale Price Method (RPM)-Resale of goods imported from its AE to third party customers without any value addition-Resale Price Method (RPM) is Most Appropriate Method (MAM).