State with brief reasons, which method of determination of Arm's Length Price (ALP) will be most appropriate in the following cases: (b) B Co. Ltd., Mumbai is engaged in manufacture of garments. It manufactured and suppl

CS Professional · Advanced Tax Laws · PYQS · December 2022
State with brief reasons, which method of determination of Arm's Length Price (ALP) will be most appropriate in the following cases: (b) B Co. Ltd., Mumbai is engaged in manufacture of garments. It manufactured and supplied as per the variation and customization in finishing of products to its associated enterprises Xylo Inc. UK as compared to the goods regularly sold to third parties.

Answer & Explanation:

B Co. Ltd, Mumbai is engaged in manufacture of garments. It manufactured and supplied as per the variations and customization in finishing of products in accordance with its Associated Enterprise i.e. Xylo Inc. However, such customization is not carried by it on the goods sold to other unrelated parties. In cases of contract manufacturing transactions with AEs, the most appropriate method is the Transactional Net Margin Method (TNMM) or Cost plus method.

Topics: Income Tax Act

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