profit to be split for
the associated enterprise from the controlled transactions in which the
associated enterprises are engaged. It then splits those profits between ... length. In general, the determination of the relevant
profits to be split and of the profit splitting factors should:
Be consistent with the functional analysis
Grounds in relation to Substantive adjustment using Residual
Profit Split Method approach
15. The Ld. AO/ Ld. TPO/ Hon'ble DRP have erred ... circumstances of the case and in law in holding Residual
Profit Split Method ('RPSM') as the MAM for benchmarking
AMP spend
margin method (TNMM).
5. erred in benchmarking the transaction by applying Profit Split Method (PSM)
even if the same was not applicable since the conditions ... Dispute Resolution Panel (DRP). However, the DRP upheld the application of
profit split method (PSM) by the TPO/AO stating that (i) an additional sale
determined by any one of the five methods, which is found to be the most
appropriate method, and goes on to lay down the manner ... methods recognized by the rule are (i) comparable uncontrolled price method
(CUP), (ii) re-sale price method, (iii) cost plus method, (iv) profit split 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
5165/Del/2016
Global One India Pvt. Ltd. vs. DCIT
following Profit Split Method and, accordingly, the Assessing
Officer should have referred the matter
Pr. Commissioner Of Income Tax - 6 vs Eight Roads Investments Advisors Pvt ... on 27 February
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
international transaction hall be determined by any of the
following methods, being the MAM, having regard to the nature
of transaction or class of transaction ... prescribe, viz.,
(a) Comparable Uncontrolled Price Method;
(b) Resale Price Method;
(c) Cost Plus Method;
(d) Profit Split Method;
(e) Transactional Net Margin Method
holding that
adjustments are required to be carried out in the operating profit
margin of the comparable companies and not the appellant.
2.9 That ... rendering IT enabled services are established to be at ALP
applying Profit Split Method as the most appropriate method and
no adjustment on account
