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low in order to get a foothold in Indian market. Since, no details and supporting documents were provided by the assessee, it is not possible to ascertain what exact functions are to be carried out by the project office vis-a-vis, HO and what risks are to be undertaken by the project office vis-a-vis HO etc. In the absence of this information, the application of CUP, in the present case, is unreliable. Since the international transaction does not involve distribution activities, RPM is also not appropriate on the facts of the case. There are no contribution of the unique intangibles from the assessee and HO and therefore, profit split method is also not applicable to the case. For the reasons mentioned in the show cause notice cost plus method is also not applicable and consequently TNMM is required to be considered as the most appropriate method, being the method of last resort.