Resale Price Method most appropriate as assessee acts as distributor and makes no value addition

PCIT-1 Vs D Light Energy P. Ltd. (Delhi High Court) Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assessee purely acts as a distributor and makes no value addition. Thus, appeal of revenue dismissed. Facts- Since assessee had entered into various international transactions with Associated Enterprises, the case was referred to TPO. The TPO, after observing that the purchase of lights/other accessories and the warranty cost claim are closely linked transactions, was of the opinion that they needed to be aggregated for ...