Transfer Pricing Methods: Internal CPM: Domestic & Export Market are not comparable

DCIT Vs Alfa Laval India Private Limited (ITAT Pune) Transfer Pricing Methods: Internal CPM :Domestic and Export Market are not comparable. Facts of the Case Alfa Laval India Private Limited is a subsidiary of Alfa Laval AB, Sweden, which holds 98.20% equity stake in the assessee company. The assessee is a leading supplier of plate and spiral exchangers, centrifugal separators and decanters, sanitary flow products and complete project and systems in India. The assessee filed its income tax return for Assessment Year 2017-18 on November 30, 2017, declaring an income of Rs. 217,55,40,530. The c...