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
length nature of its transaction, the assessee has applied the CUP method where it
has stated that the assessee has compared the royalty rates ... determining ALP? Traditional transaction methods, such as CUP, are
normally the most direct method for determining ALP. The transactional profit
split method, on the other
Ravish Lakhmani , Kolkata vs Pr.Cit - 10 , Kolkata on 13 November, 2020
IN THE INCOME
Dcit, Cir-3(1), Kolkata, Kolkata vs M/S Saregama India Ltd, Kolkata on 29
under consideration. As such, based on the said time
split, 10% of the total profit has been considered attributable to the work carried ... staffs
for the site supervision work.
• In UK- review of the construction methods being undertaken by the Indian
contractors at the site on behalf
