Board. The methods provided being (a) comparable uncontrolled price
method; (b) resale price method; (c) cost plus method; (d) profit split
method; (e) transactional ... methods i.e.
a) comparable uncontrolled price method; b) resale price method; c)
cost plus method; d) transactional net margin method; e) profit split
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 ... 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
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
property or provision of services by
the enterprise;
(d) profit split method, which may be applicable mainly in
international transactions or specified domestic transactions
involving ... profit is then split amongst the enterprises
in proportion to their relative contributions, as evaluated under
sub-clause (ii);
(iv) the profit thus apportioned
Runu Ghosh vs C.B.I. on 21 December, 2011
Author: S.Ravindra Bhat
Bench
The Commissioner Of Income Tax vs Regency Creations Ltd. on 17 September, 2012
Author: S
Cit vs Eds Electronic Data Systems (India) ... on 4 October, 2012
Author: S. Ravindra Bhat
