Delhi HC set-aside additions as TPO adopted approach contrary to rule 10B

TRANSFER PRICING : Where in case of assessee, engaged in rendering market support services to its AE, TPO proposed an additional 5 per cent mark-up on Free on Board (FOB) value of exports to third parties, in view of fact that TPO had artificially enhanced cost base of taxpayer and proposed a mark-up on FOB value of goods sourced by AEs and such approach was not available in TNMM under rule 10B(1)(e), of 1962 Rules, impugned addition was to be deleted

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