bright line
test, split the AMP expenses into routine expenses and nonroutine
expenses. The TPO chose to adopt "Profit Split Method" to bench ... Sony Ericsson (374 ITR 118)
and submitted that "Residual profit split method" is not appropriate
method to bench mark AMP transactions. He further
fact that quotation submitted were treated as
unacceptable, either Profit Split Method (PSM) or Transactional Net Margin
Method (TNMM) be accepted the additional evidences ... additional documents, under ride 46A of
the Income Tax Rules, 1961.
Profit split method: This method, is used by the appellant company now,
because
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
international transaction;
5.9. not appreciating the contribution profit split analysis ("CPSM") and Residual
Profit Split Method ("RPSM") furnished by the Appellant ... purposes of
determining routine return for application of Residual Profit Split Method
("RPSM"); and
5.11 determining the weightage of split for application
international transaction;
5.9. not appreciating the contribution profit split analysis ("CPSM") and Residual
Profit Split Method ("RPSM") furnished by the Appellant ... purposes of
determining routine return for application of Residual Profit Split Method
("RPSM"); and
5.11 determining the weightage of split for application
reducing the import price, or
(b) by applying a residual profit split method, or
(c) by getting a direct reimbursement of the excess expenditure from ... alternative might be
to apply a residual profit split method. This method would split the combined profits
from sales of the branded watches by first
Serdia Pharmaceuticals (India) Pvt. ... vs Assessee
ITA Nos: 2469/Mum/06, 3032/Mum/07 and
Yamaha Motor India Pvt. Ltd., New Delhi vs Assessee on 29 October, 2014
IN THE
including additional adjustment computed
on account of application of Profit Split Method ('PSM') as discussed
below].
15. The TPO also applied Profit Split
method;
17
ITA.No.2228 & 1863/H/2011
M/s. Tecumseh Products India P. Ltd. Hyderabad.
(c)cost plus method;
(d) profit split method ... prescribe, namely
:--
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method
