ITAT rejects TPO’s working of ALP under RPM on basis of hypothetical reseller’s profit margin

IT/ILT : Where while computing ALP of transaction of purchase of books by assessee from its AEs, TPO had not adopted profit margin of distributors on basis of actual figures or undisputed discount policies on cover prices but based on certain hypothesis which was based on misconception of facts, impugned ALP adjustment is unsustainable in law