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Ge India Industrial (P) Ltd.,, Haryana vs The Acit.,Kheda Circle,, Nadiad on 4 December

Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied ... transactions. Profits Split Method and TNM Method grouped as 'transactional profit methods', can be equally effective and reliable when applied to closely linked

Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method ... transaction or closely linked, or continuous transactions. Profits Split Method and TNM Method grouped as ‗transactional profit methods', can be equally effective and reliable

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

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

similar to what it had with M/s.Northstar and Apotex. Profit splitting with M/s. Par Pharmaceuticals was in the ratio ... Income Tax Rules, 1962. ''d) profit split method, which may be applicable mainly in international transactions involving transfer of unique intangibles

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 price method; or (b) resale price method; or (c) cost plus method; or (d) profit split method; or (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

prescribes the method s of determining ALP, having regard to the most appropriate method which will be decided in accordance with the rules prescribed. Rule ... closely linked transactions. Rule 10B(1)(d) of the Rules advocate profit split method of determining ALP where international transactions involve transfer of unique intangible