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: 1. Choice of MAM: TNMM vs. RPM: The Transfer Pricing Officer (TPO) and the Dispute Resolution Panel (DRP) favored the Transactional Net Margin Method (TNMM) as the MAM....