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Clause (a): Comparable Uncontrolled Principles Method (CUP);
Clause (b): Resale Price Method (RP) Clause (c): Cost Plus Method (CP) Clause (d): Profit Split Method (PS) Clause (e): Transactional Net Margin Method (TNMM); and Clause (f): such other Method as may be prescribed by the Board.

36. It appears from the true facts of the various cases before us and the arguments of the learned counsels that the TNNM Method appears to be the most popular and widely adopted Method for determining the 'Arm's length price' in which the Operating Profit Margin of comparable Companies are considered by the Authorities and applied to the cases of the Assessees to determined the 'Arm's Length Price' and make Transfer Pricing Adjustments.

(i) comparable uncontrolled price method (CUP), (ii) re­sale price method, (iii) cost plus method, (iv) profit split method and
(v) transactional net marginal method (TNMM). The manner by which the ALP in relation to an international transaction is determined under CUP is prescribed in clause (a) of the sub­rule (1) of Rule 10B.

The following three steps have been prescribed: ­ "(a) comparable uncontrolled price method, by which,