Tribunal held that RPM is the most appropriate method for computation of ALP when the goods are purchased from an AE resold without any substantial addition. On the facts of the assessee assembled the products after obtaining raw materials from its AE and vendors which are further improved through its own vendors and then sold to the customers. Therefore the TPO was justified in rejecting the RPM and adopting TNMM as the most appropriate method. (AY. 2012-13)
Roxtec India Pvt. Ltd. v ACIT (2021) 210 TTJ 116 / 199 DTR 1 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Assembling of products and sold to customers-TPO was justified in rejecting the RPM and adopting TNMM as the most appropriate method. [R. 10B]