Comparability depends on the company operating in wholesale or retail trade

Puma Sports India Pvt. Ltd. Vs JCIT (OSD) (ITAT Bangalore) ITAT Bangalore held that rule 10B(2)(d) of the Income Tax Rules provide that the company is in the wholesale trading and retail trading have to be considered separately for the purpose of comparison. Facts- The case was selected for scrutiny and reference was made to the Transfer Pricing Officer (TPO) to determine the arm’s length price (ALP) of the international transactions the assessee had with its associated enterprises (AE). AO determined a TP adjustment of Rs.6,65,42,022/-. Aggrieved, the assessee raised its objections before t...