accepted the benchmarking analysis applying the TNM method for
all other transactions. We find that the CUP method cannot be applied ... assessee company. As regards the remaining
methods, viz. Resale Price Method (RPM), Cost Plus Method (CPM) and Profit
Split Method (PSM), the same
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
Wrigley India Private Limited, New ... vs Assessee on 10 October, 2006
IN THE INCOME TAX
Dishman Pharmaceuticals & Chemicals ... vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD BENCH "
prescribe, namely (a)
comparable uncontrolled price method, (b) resale price method, (c) cost +
method, (d) profit split method, (e) transactional net margin method ... with transactional net margin
method (TNMM) on the adoption of which there is no dispute. In this
method the net profit margin realized
substantive basis by
applying Residual Profit Split Method ("RPSM") which is mere extension of
BLT for the purpose of benchmarking the AMP expense ... Income-tax Rules,
1962:
4.2. applying profit split ratio of 25:75 to allocate profits between the AE and
the Appellant on an arbitrary basis
senior counsel further explained that if the
profits earned by the assessee are comparable with the profits
earned by other companies in the same industry ... most appropriate method. The most
appropriate method may be a profit based method (cost plus
method, transactional net margin method or profit split method
Eli Lilly & Company (India) Pvt. Ltd., ... vs Assessee on 20 April, 2011
1 I
transaction shall be
determined by any of the following methods being the most appropriate method,
having regard to the nature of transaction or class ... prescribed namely: -
(a)comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e)Transaction net margin method
international transaction;
5.8. not appreciating the contribution profit split analysis
("CPSM") and Residual Profit Split Method (RPSM)
furnished by the Appellant during assessment ... Bright Line Test method is
used for protective adjustment and Residual Profit Split Method for substantive
adjustments, so that shows that
