The Dcit1(1), Indore vs M/S. Agrawal Coal Corporation P Ltd., ... on 8 March
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
international transaction hall be determined by any of the
following methods, being the MAM, having regard to the nature of transaction
or class of transaction ... prescribe, viz.,
a)Comparable Uncontrolled Price Method;
b)Resale Price Method;
c)Cost Plus Method;
d)Profit Split Method;
e)Transactional Net Margin Method
addition to Comparable Uncontrolled Price
(CUP) method, Resale Price Method (RPM), Cost Plus
Method (CPM), Profit Split Method (PSM) and Transactional
Net Margin Method (TNMM ... Method (RPM) and Cost Plus Method (CPM),
has an inherent edge over indirect methods such as
Transactional Net Margin Method (TNMM) and Profit Split
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
namely :-- (a) comparable
uncontrolled price method; (b) resale price method; (c) cost plus method;
(d) profit split method; (e) transactional net margin method; (f) such
transaction shall be
determined by any of the following methods, being the most
appropriate method, having regard to the nature of transaction ... 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
international transactions or specified domestic transactions
involving ... profit is then split amongst the enterprises
in proportion to their relative contributions, as evaluated under
sub-clause (ii);
(iv) the profit thus apportioned
Dcit 1(3), Mumbai vs Syngenta India Ltd, Pune on 30 November, 2016
आयकर अपीलीय
M/S. J. J. Exporters Ltd., Kolkata vs Dcit, Circle - 11(1), Kolkata, Kolkata on