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TPO can apply TNMM to compute ALP even if comparable Co. isn't manufacturing exactly the same product

March 6, 2019[2019] 102 422 (Kolkata - Trib.)

IT/ILT : Unlike CUP Method TNMM does not require that comparable company has to manufacture exactly same product as that manufactured by tested party

IT/ILT : Companies which were manufacturing and selling electronic components, Electronic radiators, Soft ferrite, Electronic printed circuit boards, Aluminium electrolytic capacitors, Electronic capacitor grade metalised polypropylene film, etc., were functionally comparable to assessee-company manufacturing soft ferrites components

IT/ILT : Application of 'cash profit margin', under TNMM, in manufacturing industry is appropriate for reason that same eliminates impact on profitability of differences in respect of technology, age of assets used in production, capacity utilization and depreciation expenses and its policies and interest expenses

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