Wholesale & Retail Markets Cannot Be Treated Alike for TP Benchmarking: ITAT Delhi

Astemo India Private Limited Vs ACIT (ITAT Delhi) The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) decided two appeals filed by the assessee for Assessment Years 2016–17 and 2017–18 concerning transfer pricing adjustments in the trading segment and a separate disallowance under Section 40(a)(ia). The assessee was engaged in the business of selling Electronic Control Units, fuel injection parts, and CNG assembly parts. It purchased goods from Associated Enterprises (AEs) and unrelated parties and sold them mainly to unrelated parties. For benchmarking its international transactio...