Document Fragment View
Fragment Information
Showing contexts for: Profit Split Method in Dongfang Electric Corporation, ... vs Acit (International Taxation), Circle ... on 17 May, 2019Matching Fragments
Further, reference is made to Rule 10B(1)(d) of the Rule which states that Profit Split Method ('PSM') may be applicable in cases where transactions involved transfer of unique, intangible or any multiple interrelated international Pa g e | 1 2 ITA Nos.2563 & 2564/Kol/2017 Dongfang Electric Corporation transactions, which cannot be evaluated separately for determining the arm's length price of any one transaction.