erred in law and on facts, in applying Profit Split Method ("PSM") to
benchmark the alleged international transaction of incurring excessive AMP
expenditure ... assessee are removed and not of the AE,
the PSM (Profit Split Method) calculation will go wrong.
3. The appellant craves to amend, modify, alter
License fees CUP 2,51,34,745
Search fees reed Profit Split Method(PSM) 3,14,87,717
Client billed Expenses reed Profit Split Method ... Multicountry Execution Assignment reed Profit Split Method(PSM) 1,02,84,090
Services fee paid Profit Split Method(PSM) 2,90,51,116
Multicountry Execution
At&S India Private Limited, Karnataka vs D.C.I.T., Circle-11(1
been treated as
business profit of the group members and
these have been apportioned by adopting a
profit split method. The Profit Split Method
required
method applied for
making the adjustments in the various years are as under:
AMOUNT IN RS.
A.Y. ADJUSTMENT AS METHOD ADJUSTMENT AS METHOD
COMPUTED ... wherein the Ld. TPO
has computed the adjustment by applying Profit Split Method
("PSM"); and
c) Appeals for A.Y. 2013-14, wherein
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
Ge India Industrial (P) Ltd.,, Haryana vs The Acit.,Kheda Circle,, Nadiad on 4 December
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
namely :-- (a) comparable
uncontrolled price method; (b) resale price method; (c) cost plus method;
(d) profit split method; (e) transactional net margin method; (f) such
M/S. J. J. Exporters Ltd., Kolkata vs Dcit, Circle - 11(1), Kolkata, Kolkata on
