prescribe, namely (a) comparable uncontrolled price method; (b) resale price method;
(c) cost plus method; (d) profit split method; (e) transactional net margin method ... that is where indirect methods or
transactional profit methods such as TNMM (transactional net margin method) and PSM
(profit split method), may actually have
administration, selling and distribution overheads
borne by the AE while applying CUP method, has not been done, and the ldTPO erred in
comparing different sized ... method: (a) comparable uncontrolled price method (hereafter CUP method);
(b) resale price method (hereafter RPM); (c) cost plus method (hereafter CPM); (d)
profit split method
property or provision of services by
the enterprise;
(d) profit split method, which may be applicable mainly in
international transactions involving transfer of unique
intangibles ... profit is then split amongst the enterprises
in proportion to their relative contributions, as evaluated under
sub-clause (ii);
(iv) the profit thus apportioned
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
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
most appropriate
method lies on the assesses. In this case the use of CPM (Cost
Plus method) and RPM (Resale Price method) is ruled ... assessee does not have substantial intangibles, the
use of PSM (Profit Split Method) is also ruled out. Thus the use
of TNMM is most appropriate
resale
price method in the instant case. We find as per 10B(1)(b) of
the Income-tax Rules, re-sale price method could ... sale price method is
traditional transaction method which would always be
preferable to transactional profit method like profit split
method and TNMM.
6.6 Yet another
Shanghai.
9
ITA No.554/PUN/2024, AY 2016-17
9.4.3.4. Profit split method
Lear Shanghai does not own any non-routine intangibles and further ... information pertaining to the gross profit
mark-up in case of similar transactions is unavailable.
iv. Profit Split Method: Generally adopted in case where unique
