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Showing contexts for: Profit Split Method in M/S. Mckinsey Knowledge Centre India ... vs Pr. Commissioner Of Income Tax, Delhi 6 on 9 August, 2018Matching Fragments
24. Section 92C (1) of the Act contains provisions in relation to various methods of calculation of ALP, it envisages five methods, namely (a) comparable uncontrolled price method, (b) resale price method, (c) cost plus method, (d) profit split method, (e) transactional net margin method, (f) any such other method as may be prescribed by the board, with regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors as the board may prescribe; read with Rule 10B of the Income Tax Rules, 1962 which provides for calculation/determination of ALP. Where more than one price is determined by the most appropriate method, the Arm‟s Length Price shall be taken to be arithmetical mean of such prices. Rule 10B(2) describes the grounds on which the comparability of an international transaction (or a specified domestic transaction) with an uncontrolled transaction should be based on. This sub-rule reads as follows: