RPM method not to be used if assessee was also engaged in other activities apart from importing equipments from AE

IT/ILT: Where assessee having imported cranes and mechanical equipments from AE, supplied same to Indian customers, in view of fact that apart from import of cranes from AE, assessee also performed various other functions such as market research, requirement analysis, quality checks, etc., RPM method could not be used to determine ALP of international transactions entered into with AE

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