transaction]
shall be determined by any of the following methods, being
the most appropriate method, having regard to the nature of
transaction or class ... comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(4) profit split method;
(e) transactional net margin method;
(f) such other 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 ... comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(4) profit split method;
(e) transactional net margin method;
(f) such other method
Profit Split Method (PSM) is Most Appropriate Method
(MAM) and the Comparable Uncontrolled Price Method (CUP) adopted by
the petitioner ... products and also
shares some of the marketing responsibilities the profit sharing ratio is fixed
at 70:30 (70 to the petitioner
Most Appropriate Method' by the
Authorities under the Act. The methods
provided are:
Clause (a): Comparable Uncontrolled
Principles Method (CUP);
Date of Judgment ... Clause (b): Resale Price Method (RP)
Clause (c): Cost Plus Method (CP)
Clause (d): Profit Split Method (PS)
Clause (e): Transactional Net Margin
Method (TNMM
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
Comparable Uncontrolled
Principles Method (CUP);
Clause (b): Resale Price Method (RP)
Clause (c): Cost Plus Method (CP)
Clause (d): Profit Split Method (PS)
Clause ... learned counsels that the TNNM Method appears
to be the most popular and widely adopted
Method for determining the 'Arm's length price
department disallowed the partial claim by
applying Profit Split Method (PSM) resulting into splitting the total profit from the
27
ITA No. 1517/JP/2024 ... department disallowed the partial claim by applying
Profit Split Method (PSM) resulting into splitting the total profit from the said
activity into profit attributable
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
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
partytothe controlled transactions
Lg Electronics India Private ... vs Deputy Commissioner Of Income Tax, ... on 15 October, 2025
INCOME
