Topcon Sokkia India (P.) Ltd. v. DCIT(2020) 183 ITD 876 (Delhi) (Trib.)

S. 92C : Transfer pricing-Arm’s length price-Re sale without any further value addition-Resale Price Method (RPM) is most appropriate method for determining ALP of said international transactions.

During relevant year assessee purchased certain finished goods from AE and resold same to various customers in India. In order to benchmark said transactions assessee adopted Resale Price Method.  TPO, however, taking a view that TNMM was most appropriate method. DRP upheld order passed by TPO. Tribunal held that when assessee purchases products from AE and resells same without any further value addition or further processing then RPM is most appropriate method for determining ALP of said international transactions. (AY. 2014-15)