same.
The contention of the complainant that starting from 2001 the CPM
Policy is regularly taken from the insurer is subject to verification.
Even ... terms of the
policy, which in the present case was CPM Policy. The O.P.No.3 has
thus considered all the above aspects while
assessee that it has applied cost plus method (CPM).
He submitted, as per foreign trade policy of the Government, the
minimum value addition ... price charged to its A.E. by applying CPM on the
basis of foreign trade policy. The bench mark done by the assessee
was rejected
OECD Guidelines. Hence with
regard to correct application of CPM or TNMM, the Associated Enterprises of the assessee
should be selected as tested party ... Subsequently, an analysis of gross margin or net margin by applying either CPM or TNMM
retained by AEs should be undertaken for benchmarking the transaction
studded
jewellery. The only reason given for adopting the cost plus
method (CPM) and for rejecting the transaction net margin
method (TNMM) of assessee ... discussed in his order as to how
he has arrived at CPM as the most appropriate method and
TNMM is not the most appropriate method
Pema Khandu & 10 Ors vs Nabam Rebia on 13 January, 2016
Equivalent citations: AIR
Ranbaxy Laboratories Ltd., New Delhi vs Assessee on 25 April, 2016
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