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a)Comparable Uncontrolled Price Method;

b)Resale Price Method;

c)Cost Plus Method;

d)Profit Split Method;

e)Transactional Net Margin Method;

f)Such other method as may be prescribed by the Board.

IT(TP)A No.187/Bang/2015 Sub-section2 of Section 92C of the Act provides that the MAM referred to in sub- section (1) shall be applied, for determination of the ALP, in the manner as may be prescribed.

Rule 10B of the IT Rules, 1962 provides for the determination of ALP under Section 92C of the Act. The TPO in the case on hand has applied CPM as the MAM. Rule 10B(1)(c) deals with the determination of ALP as per CPM and the same is extracted hereunder :-