transaction shall be determined
by any of the following method, being the most appropriate method having regard to the
nature of transaction, class 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
acceptable since in manufacturing there is no resale and profit
split method is not before us. Further, the assessee in its TP study itself
adjustment purely on estimate basis without following any
approved method for determination of arm's length price as prescribed
under the statutory provisions. Thus ... most appropriate method prescribed are as
under:-
i) Comparable Uncontrolled Price Method;
ii) Resale Price Method;
iii) Cost Plus Method;
iv) 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
Rule 10B(1)(d) of the Rule which states that Profit
Split Method ('PSM') may be applicable in cases where transactions involved
transfer ... length price of any one transaction.
This method involves determination of overall profit of the associated enterprises
arising out of the international transactions undertaken
also been
informed to us that above principle of 50:50 Profit Split are a
widely accepted pricing formula prevalent across the global
freight-forwarding ... taxmann.com 384 (Kolkata-
Trib.), wherein 50:50 profit split method has been upheld. In the
said case this issue had come up for, wherein
capable of being owned or controlled by an
individual enterprise.
48. Profit Split method would be applicable mainly in
international transaction involving transfer of unique ... view of Indian Government) which
advocates use of profit split method for allocation of location
savings is not correct.
49. The assessee also argued that
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
appropriate method,
such as(a) comparable uncontrolled price method; or (b) resale price method; or (c) cost
plus method; or (d) profit split method
