Dissimilar products cannot be taken to determine gross margin by RPM

Elcome Technologies Private Limited Vs DCIT (ITAT Mumbai)

Resale Price Method (RPM) is a GP margin based method. It is a traditional transaction method. It primarily compares controlled and uncontrolled transactions. Under RPM we can tolerate slight differences in the products distributed by the two types of distributors as long as the broad category of products distributed is the same.

As mentioned earlier while product differences may be more acceptable in applying the RPM as compared to

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