RPM most appropriate method for trading segment

Karcher Cleaning Systems Pvt Ltd. Vs ACIT (ITAT Delhi)

The assessee is a pure trading company involved in the distribution activity without adding any value to the purchased product and hence the RPM is the most appropriate method.
Facts-

The assessee is a subsidiary of Karcher Beteilgungs GmbH which started its commercial activities on 16.04.2011 and is primarily engaged in the business of importing and resale of industrial cleaning systems in India.

Transaction pertaining to the purchase of goods for the purpose of resale in India has also been analyzed using Internal Comparable Uncontrolled Price Method.

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