Tribunal held that the assessee had not resold the same goods with only minor modifications to justify the adoption of resale price method. The assessee had assembled the goods partly purchased from its associated enterprise and partly developed them by its own vendor. There was no infirmity in the order of the Assessing Officer/Transfer Pricing Officer as well as direction of the Dispute Resolution Panel in adopting the transactional net margin method as the most appropriate method. (AY. 2013-14)
Roxtech India Private Ltd. v. ACI T (2021) 86 ITR 42 (SN) (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Arm’s Length Price-Most Appropriate Method-Assembling goods partly purchased from its associated enterprise and partly developed by its own vendor-Resale Price Method adopted is not appropriate-Transactional Net Margin Method, Appropriate. [S. 144C]