TNMM is most appropriate Method for international sale of finished goods

DCIT Vs Ampacet Speciality Products Private Limited (ITAT Pune) ITAT Pune held that in view of huge quantitative differences, Comparable Uncontrolled Price (CUP) method cannot be applied. Hence, Transactional Net Margin Method (TNMM) is applicable in respect of international transaction of ‘Sale of Finished Goods’. Facts- The assessee is a domestic company engaged in the manufacturing of colour concentrates and additive masterbatches. In addition, it is also engaged in trading activities. AO made a reference to the Transfer Pricing Officer (TPO) for determining the Arm’s Length Price (AL...