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:
(i)comparable uncontrolled price method;
(ii) resale price method;
(iii) costs plus method;
(iv) profit split method;
(v) 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 ... namely :
(a) comparable uncontrolled price method ; (CUP)
(b) resale price method ; (RPM)
(c) cost plus method ; (CPM)
(d) profit split method ; (PSM)
(e) transactional
Profit Split Method (PSM) is Most Appropriate Method
(MAM) and the Comparable Uncontrolled Price Method (CUP) adopted by
the petitioner ... products and also
shares some of the marketing responsibilities the profit sharing ratio is fixed
at 70:30 (70 to the petitioner
transaction shall be determined by any of the
following methods, being the most appropriate method, having
regard to the nature of transaction or class ... namely :
(a) comparable uncontrolled price method ; (CUP) (b) resale
price method ; (RPM) (c) cost plus method ; (CPM) (d) profit split
method ; (PSM) (e) transactional
have been introduced in Schedule 1 to the Excess Profits Tax Act. After computing the profits in that manner, if the accounting period does ... Schedule 1 to the Excess Profits Tax Officer to split up the period with a view to ascertain the profits from the accounts
would be seen that the unit for computation of the profits under the Excess Profits Tax Act is the accounting period which is a period ... Schedule I to the Excess Profit Tax Officer to split up the period with a view to ascertain the profits from the accounts
receipt and having
regard to the completed contract method to arrive at the
Profit and Loss Account, the question of spreading over to
five years ... that in adopting the completed contract method,
the computation had resulted in an unrealistic picture on
the right profit and loss.
34. The finding
levied on the profits or gains arising from certain stated transactions after a particular date. Such profits and gains are to be deemed ... have to find out what are profits and gains in the transaction. Such profits and gains would then have to be deemed to be income
interest of the partners, are mere variations of the method of adjustment of the profits, there should be no impediment in treating them as part ... partner, stand attenuated. The mere fact that the transactions are split into or spread over two or more accounts should not, by itself, make
