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Showing contexts for: Profit Split Method in Ksb Pumps Ltd, Mumbai vs Assessee on 5 August, 2013Matching Fragments
(a) Comparable Uncontrolled Price method(CUP); (b) Resale Price method; (d) Cost plus method; (d) Profit Split method; (e) Transaction Net Margin Method(TNMM); such other method as may be described by the Board."
As it can be seen from the above list of international transactions that none of the international transactions match to each other. Therefore, it cannot be said that a common method will be sufficient to compute the ALP as firstly it has to be determined that which method will be appropriate method to compute the ALP of an international transaction. There is no dispute with regard to other international transactions which have been accepted by the TPO. The dispute is only in respect of commission payment. It is the case of M/s.KSB Pumps Ltd..