Under RPM, Focus on Functional Similarity, Not Product Similarity: ITAT Mumbai

Troy Chemicals India Pvt. Ltd Vs CIT(A) (ITAT Mumbai) ITAT Mumbai under Resale Price Method [RPM] focus is more on same or similar nature of products rather than similarity of products. Thus, TPO directed to include 5 companies as comparable for benchmarking international transaction. Facts- The assessee is a subsidiary of Troy Corporation, USA and is primarily engaged in the trading of specialty chemicals, additives, etc., in India. During the year under consideration, the assessee has entered into an international transaction with Troy Siam Company Ltd., which is incorporated under the laws ...