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At&S India Private Limited, Karnataka vs D.C.I.T., Circle-11(1

made:- (i) By applying Transactional Net Margin Method and rejecting Comparable Uncontrolled Price method or Profit Split Method for determining the amount of profit ... made:- (i) By applying Transactional Net Margin Method and rejecting Comparable Uncontrolled Price method or Profit Split Method for determining the amount of profit

Profit Split Method (PSM) and objected on the TNMM method applied by the undersigned as the Most Appropriate Method (MAM) On perusal of details ... Group Profit had not been compared with any external comparable to verify the Profit Split. As a result, the adoption of TNMM Method, the comparison

namely :- 4 (a) comparable uncontrolled price method; (b) resale price method; (c) cost plus method; (d) profit split method; (e) transactional net margin method ... comparable uncontrolled price method; (b) resale price method; (c)cost plus method; (d)profit split method; (e)transactional net margin method; (f)such other method

Method, i.e. Comparable Uncontrolled Price Method, RP Method, i.e. Resale Price Method and CP Method, i.e. Cost Plus Method can be applied ... transactions. Profits Split Method and TNM Method grouped as 'transactional profit methods', can be equally effective and reliable when applied to closely linked

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

M/S. J. J. Exporters Ltd., Kolkata vs Dcit, Circle - 11(1), Kolkata, Kolkata on

allocated lower cost to the related party so as to increase its profitability and consequent to it, held that the Internal TNMM ... profit. As calculation of GP is very subjective and the India Accounting Standards does not provide for the presentation of gross profit. 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

uncontrolled price method ( CUP method); (b) resale price method ( RPM); (c) cost plus method (CPM); (d) profit split method (PSM); (e) transactional net margin method ... resale price method; (c) cost plus method; (d) profit split method; (e) transactional net margin method; (f) such other method as may be prescribed