entire profitability is wipped off, there is nil profit to be attributed to the
entities on account of profit split method. In view of this ... which is resulting in nil profit to it. Therefore
there cannot be any reason to apply the profit split method to share the
profit
method for determining the arm's length price.
84. OFCD guidelines for profits spilt method (PSM) states as under:-
C. Transactional profit split method ... split the combined profits.
C.2 Strengths and weaknesses
2.109 The main strength of the transactional profit split method is that it can
offer
justified in holding the Profit Split Method is the Most Appropriate
ITA No. 1639/Ahd/2024
DCIT vs. Indianic Infotech Ltd.
Asst.Year ... Associated
Enterprise (AE) and found that the assessee had adopted the Profit Split
Method (PSM) as the Most Appropriate Method (MAM). The assessee
contended that
tested party for comparability only in CUP method,
TNMM and 'Other method', in other methods such as RPM and CPM choice
of selecting ... available. In any case, it is not required in
Profit split method.
(b) The tested party normally should be the least complex party
tested party for comparability only in CUP method, TNMM and 'Other
method', in other methods such as RPM and CPM choice of selecting ... available. In any case, it is not required in Profit split method.
(b) The tested party normally should be the least complex party
unique intangibles from the assessee and HO and therefore,
profit split method is also not applicable to the case. For the reasons mentioned ... TNMM is required to be considered as the most appropriate method, being the
method of last resort.
12. The assessee objected for TNMM
Atul Limited,, Ahmedabad vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD BENCH "D
tested party for comparability only in CUP method, TNMM and
'Other method', in other methods such as RPM and CPM choice of selecting ... available. In any case, it is not required in Profit split method.
(b) The tested party normally should be the least complex party
The Dy. Cit, Circle-2(1)(1),, ... vs M/S. Gujarat Microwax Ltd.,, Ahmedabad on
Dishman Pharmaceuticals & Chemicals ... vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD BENCH "
