international transactions with its associate enterprises. The
assessee has applied PSM (profit split method) for benchmarking international
transactions with the AE. The assessee has justified ... under the method, i.e. the profits earned by the AE and assessee
from each transaction so that profit could be split having reasonable basis
following methods:
(a) Comparable Uncontrolled Price Method (CUPM)
(b) Resale Price Method (RPM)
(c) Cost Plus Method (CPM)
(d) Profit Split Method (PSM)
(e) Transactional ... prescribe, namely:-
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method
Board. The methods provided being (a) comparable uncontrolled price
method; (b) resale price method; (c) cost plus method; (d) profit split
method; (e) transactional ... methods i.e.
a) comparable uncontrolled price method; b) resale price method; c)
cost plus method; d) transactional net margin method; e) profit split
method
financial result of merchant
banking activity (with low profit margin) would result in profit margin of total
entity getting reduced and thus, such comparables ... perfect
comparables could be found, then use of other methods like profit split method
might be explored.
5.7 On the proposition
prescribe, namely :-
(a)comparable uncontrolled price method;
(b) resale price method;
(c)cost plus method;
(d)profit split method;
(e)transactional net margin method ... prescribe, namely
(a) comparable uncontrolled price method, (b) resale price method, (c) cost
+ method, (d) profit split method, (e) transactional net margin method
prescribe, namely:
(i). Comparable Uncontrolled Price method;
(ii). Resale Price Method;
(iii).Cost Plus Method;
(iv). Profit Split Method;
(v). Transactional Net Margin Method ... appropriate method, the TPO therefore
deliberated on Rule 10B(1)(e) which prescribed the methodology for
determining the ALP as per the said method
prescribe, namely : -
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method ... prescribe, namely (a) comparable uncontrolled price method,
(b) resale price method, (c) cost + method, (d) profit split
method, (e) transactional net margin method
that a part of the Assessee‟s income,
computed on profit split method, is chargeable to tax under the Act.
2.2 Whilst the Assessee claims ... 2013, 2385/2013 & 2390/2013 Page 5 of 31
apply Profit Split Method (PSM) for determining the ALP instead of
Transactional Net Marginal Method
made by the Assessing Officer/Transfer Pricing
Officer on account of profit split method, ignoring that the Transfer
Pricing Officer rejected the CUP method after ... made by the AO/TPO by applying profit split method,
ignoring the fact that TPO has rejected the CUP method after
30
Tolani Shipping
At&S India Private Limited, Karnataka vs D.C.I.T., Circle-11(1
