If assessee resold goods imported from AE without any value addition, than most appropriate method for determining ALP is RPM

Randox Laboratories India Private Limited Vs ACIT (ITAT Bangalore) The core issue arising for consideration is, whether the international transaction relating to purchase of reagents, spares, consumables from the AE is a simple trading activity, hence, can be benchmarked under RPM. Before we advert to the core issue, it is necessary to understand the activities of the assessee with its AE. As stated earlier in the order, assessee’s AE is manufacturing medical diagnostic reagents, analyzers and consumables. Assessee imports these reagents form the AE and sells them to diagnostic units / l...