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Showing contexts for: Profit Split Method in Casio India Company Private Ltd. , Delhi vs Dc/Acit/Tp-1(2)(1), Delhi on 19 July, 2022Matching Fragments
14. erred in making inappropriate selection of comparable companies for the mark-up on alleged AMP expenditure while computing adjustment.
Grounds in relation to Substantive adjustment using Residual Profit Split Method approach
15. erred on facts and circumstances of the case and in law in holding Residual Profit Split Method ('RPSM') as the most appropriate method ('MAM') for benchmarking AMP spend.
5 ITA No. 1956/Del/2021Casio India company Pvt. Ltd.
5. Aggrieved by the final assessment order, the present appeal has been preferred by the assessee on the grounds mentioned above.
6. The Assessee's Grounds No. 1 & 2 are general in nature. Ground No. 3 to 7 in respect of treating of AMP as international transaction, Ground No. 8 is in respect of exclusion of selling and distribution expenses. Ground No. 9 challenging the exclusion of comparable Companies. Grounds No. 10 to 14 on protective adjustment applying bright line test. Ground No. 15 & 16 on substantive adjustment applying residual profit split method. Ground No. 17 is consequential.