Held that property is purchased by an Indian enterprise from its AE and is resold as such without any value addition, it is RPM, being specific method, which would hold field in preference to TNMM Percentage of related party transactions of expenses of selected company was more than 57 per cent of total expenses incurred by it, selected company could not be held as comparable-Tribunal also held that companies engaged in assembly activity,,engaged in multi-dimensional ranging business and also into field of constructing, production of electronic weighing scales, currency counting machine-business of manufacturing, marketing and servicing of road and rail weigh bridges are cannot be considered as comparable. Addition is deleted. (AY. 2017-18)
Vega India Level and Pressure Measurement (P.) Ltd v. Dy. CIT(2023) 223 TTJ 242/ [2022] 145 taxmann. com 472(Pune)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Property is purchased by an Indian enterprise from its AE and is resold as such without any value addition, it is RPM, being specific method, which would hold field in preference to TNMM-Percentage of related party transactions of expenses of selected company was more than 57 per cent of total expenses incurred by it, selected company could not be held as comparable-Comparable-Assembly activity-Engaged in multi-dimensional ranging business and also into field of constructing-production of electronic weighing scales, currency counting machine-business of manufacturing, marketing and servicing of road and rail weigh bridges-Not comparable. [S. 92CA]