Transfer price adjustment is warranted

No TP adjustments is warranted if GP rate of assessee as per RPM method exceeds comparable’s GP rate

Where assessee-company was engaged in distribution of telecom equipments on behalf of its AE, in view of fact that by applying resale price (RPM), GP as percentage of sales shown by assessee was much higher than GP as percentage of sales arrived at in case of comparables selected by TPO, no adjustment could be made to ALP determined by assessee