RPM Most Appropriate for ALP in Absence of Distributor’s Value Addition to Goods

PCIT Vs Fujitsu India Private Limited (Delhi High Court)

Introduction: The Delhi High Court addressed significant issues in the case of PCIT vs. Fujitsu India Private Limited concerning Assessment Years 2011-12, 2012-13, and 2013-14. The primary question of law focused on the selection of the Most Appropriate Method (MAM) for determining the Arm’s Length Price (ALP) in the context of transfer pricing.

Detailed Analysis:

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