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
rejecting the benchmarking analysis of the assessee and
applying the profit split method as the most appropriate method. The benchmarking done
by the assessee being ... record. Considering these facts the Ld. TPO applied profit split method by
dividing profits in the ratio of contribution made by each unit
there are prescribed
methods under transfer pricing guidelines which has to be followed while
benchmarking any of the transaction. The methods prescribed under the
Income ... Comparable Uncontrolled Price Method
2. Transactional Net Margin Method
3. Resale Price Method
4. Cost Plus Method
5. Profit Split Method and
6. Any Other
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
M/S Widex India Pvt. Ltd., Chandigarh vs Acit, Chandigarh on 23 May, 2019
आयकर
been reflected in profit & loss account. He, therefore, recasted trading-cum-profit & loss account by including cost of work-in-progress ... recasting trading-cum-profit & loss account, the assessee had submitted that all throughout it had been following the same method of accounting. Even
Deputy Commissioner Of Income Tax vs Glaxo Smithkline Consumer Healthcare ... on 20 July, 2007
Equivalent
Deputy Commissioner Of Income Tax vs Industrial Cables (I) Ltd. on 24 October, 2003
Equivalent
Avon Cycles Pvt. Ltd. vs Inspecting Assistant Commissioner Of ... on 2 September, 1993
Equivalent citations
Dcit, Chandigarh vs M/S Ind Swift Ltd., Chandigarh on 11 August, 2017
IN THE