performed,
perhaps as part of a residual profit split or as a
method of splitting profits in its own right, by taking
into account ... intangible property. The profit is to be divided
such as is expected in a joint venture relationship.
6.3.13.2. The Profit Split Method seeks to eliminate
profits to be split. It then splits those combined profits between the
associated enterprises on an economically valid basis that
approximates the division of profits ... split method will
generally be the most appropriate method, see paragraph 2.109.
However, a one-sided method (traditional transaction method or
transactional net margin method
Sony Ericsson Mobile Communications ... vs Commissioner Of Income Tax ??? Iii on 16 March, 2015
Author
prescribe, namely :-
(a)comparable uncontrolled price method;
(b) resale price method;
(c)cost plus method;
(d)profit split method;
(e)transactional net margin method ... prescribe, namely
(a) comparable uncontrolled price method, (b) resale price method, (c) cost
+ method, (d) profit split method, (e) transactional net margin method
that the assessee was inadequately
compensated by its AEs and the Profit Split Method (PSM) had to be
applied for determining ... assessee has submitted its reply on 05.10.2011 towards the
use of Profit Split Method. The main contentions of the assessee
is that the key conditions
including additional adjustment computed
on account of application of Profit Split Method ('PSM') as discussed
below].
15. The TPO also applied Profit Split
than others, on a
conceptual note, transactional profit methods (i.e.
Transactional Net Margin Method and Profit Split
Method) are treated as methods of last ... prescribe24, namely :--
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin 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 ... property or
provision of services by the enterprise;
(d) profit split method, which may be applicable mainly in
ITA 102/2015 Page
capable of being owned or controlled by an
individual enterprise.
48. Profit Split method would be applicable mainly in
international transaction involving transfer of unique ... view of Indian Government) which
advocates use of profit split method for allocation of location
savings is not correct.
49. The assessee also argued that
considered as operating expense. Since the Assessing Officer
has adopted TNMM method on a company wide basis, so we
first go to the relevant rules ... appropriate method in the
following manner namely:-
a) Comparable uncontrolled price method,
b) Resale price method,
c) Cost plus method,
d) Profit split method
