case of
indenting the CUP method was the most appropriate method,
therein adopted the Profit Split Method ('PSM') as the most
appropriate ... split the profit on 50:50 basis taking GP/Cost ratio of
21.28%, therein directed the TPO to modify his order and
split the profit
prescribe, namely:
(i). Comparable Uncontrolled Price method;
(ii). Resale Price Method;
(iii).Cost Plus Method;
(iv). Profit Split Method;
(v). Transactional Net Margin Method ... appropriate method, the TPO therefore
deliberated on Rule 10B(1)(e) which prescribed the methodology for
determining the ALP as per the said method
method is not acceptable to TPO , he could
have modified it to Profit S plit method to compute ALP but
outright rejection of the method ... only profit split
method is acceptable to compute the ALP . It was submitted that
there is no such Revenue Split method as adopted
Ultra Tech Cement Ltd, Mumbai vs Addl Cit Rg 2(2), Mumbai on 5 April
Dcit Cen Cir 40, Mumbai vs Saf Yeast Co. P. Ltd, Mumbai on 24 November
New Holland Fiat (I) P.Ltd, Mumbai vs Dci Rg 10(1), Mumbai on 3
Dcit Cen Cir 40, Mumbai vs Saf Yeast Co. P. Ltd, Mumbai on 24 November
Database Software Technology P.Ltd, ... vs Ito 3(1)(2), Mumbai on 7 July, 2017
New Holland Fiat (I) P.Ltd, Mumbai vs Dci Rg 10(1), Mumbai on 3
Ranjeet D Vaswani, Mumbai vs Acit 12(3), Mumbai on 19 April, 2017
IN THE
