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
other methods provided are cost plus method which is
applicable to the transactions relating to manufacture and sale of
goods and Profit Split Method which ... These two methods cannot be made
applicable to the facts before us. The only remaining method is the
Transactional net margin method (TNMM)by which
rejected by the TPO and
he held that TNMM method to be the most appropriate method for
determining the international transactions.
16. We find that ... than others, on a conceptual note, transactional profit
methods (i.e. Transactional Net Margin Method and Profit Split Method)
are treated as methods of last
demonstrate that this international transaction was at ALP, the assessee
applied Profit Split Method (PSM) as the most appropriate method. In the
absence
Atul Limited,, Ahmedabad vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD BENCH "D
explained that Section 92C has provided
different methods to compute Arm's Length Price. Those
methods are provided under six categories, running from ... company. It is
also equally not possible to apply Profit Split Method (PSM). The
Transactional Net Margin Method (TNMM) is also not applicable
as there
received INR 28,00,00,000/- from BCCI. Adopting the
profit split method prescribed under the Indian Transfer Pricing
Regulations, it had attributed revenue
received INR 28,00,00,000/- from BCCI. Adopting the
profit split method prescribed under the Indian Transfer Pricing
Regulations, it had attributed revenue
received INR 28,00,00,000/- from BCCI. Adopting the
profit split method prescribed under the Indian Transfer Pricing
Regulations, it had attributed revenue
received INR 28,00,00,000/- from BCCI. Adopting the
profit split method prescribed under the Indian Transfer Pricing
Regulations, it had attributed revenue
