Adjustment for variation in closing stock necessary for correct application of TNMM

Brief of the case:                               ITAT Licknow in the case of ACIT vs. M/s Rahman Industries Ltd. held that Adjustment for variation in closing stock is necessary for the correct computation of Operating cost thereby correct application of Transaction Net Margin Method (TNMM). Resale price method for computing ALP cannot be used in case of exporters Facts of the case: The assessee company has entered some international transactions for the relevant AY. The AO referred those cases to Transfer Pricing Officer(TPO) to ascertain whether the transfer...