determined by any one
of the five methods, which is found to be the most appropriate
method, and goes on to lay down the manner ... methods recognized by the rule
are (i) comparable uncontrolled price method (CUP), (ii) re-sale
price method, (iii) cost plus method, (iv) profit split 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 ... property or
provision of services by the enterprise;
(d) profit split method, which may be applicable mainly in
ITA 102/2015 Page
transaction shall be determined by any of the following methods, being the most appropriate method, having regard to the nature of transaction or class ... prescribe, namely:
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method
transaction shall be determined by any of the following methods,
being the most appropriate method, having regard to the nature of
transaction or class ... prescribe, namely: (a) Comparable uncontrolled price
method; (b) Resale price method; (c) Cost plus method; (d) Profit split
method; (e) Transactional net margin method
tested party for comparability only in CUP method,
TNMM and 'Other method', in other methods such as RPM and CPM choice
of selecting ... available. In any case, it is not required in
Profit split method.
(b) The tested party normally should be the least complex party
method applied for
making the adjustments in the various years are as under:
AMOUNT IN RS.
A.Y. ADJUSTMENT AS METHOD ADJUSTMENT AS METHOD
COMPUTED ... wherein the Ld. TPO
has computed the adjustment by applying Profit Split Method
("PSM"); and
c) Appeals for A.Y. 2013-14, wherein
transaction shall be determined by any of the following
methods, being the most appropriate method, having regard to the nature
of transaction or class ... prescribe , namely :--
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method
tested party for comparability only in CUP method, TNMM and 'Other
method', in other methods such as RPM and CPM choice of selecting ... available. In any case, it is not required in Profit split method.
(b) The tested party normally should be the least complex party
profit. Even for the asst. yr. 1998-99, it was 49.94 per cent of the profit before tax. The assessee was throughout making its case ... There were several methods laid down such as comparable uncontrolled price method; resale price method; cost plus method; profit split method and transaction net margin
relation to an „international transaction; could be determined by any of
the methods provided in the said sub-section which is „most appropriate‟
having regard ... Board. The
methods provided being (a) comparable uncontrolled price method; (b)
resale price method; (c) cost plus method; (d) profit split method; (e)
transactional
