following methods, being the most appropriate method–– (a) comparable uncontrolled price method; (b) resale price method; (c) cost plus method; (d) profit split method
However, the TPO separately benchmarked the royalty payment
using the Profit Split Method (PSM) as the most appropriate method and
made the necessary adjustment ... length. In general,
the determination of the relevant profits to be split and of the
profit splitting factors should: Be consistent with the functional
analysis
international transaction;
5.9. not appreciating the contribution profit split analysis ("CPSM") and Residual
Profit Split Method ("RPSM") furnished by the Appellant ... purposes of
determining routine return for application of Residual Profit Split Method
("RPSM"); and
5.11 determining the weightage of split for application
international transaction;
5.9. not appreciating the contribution profit split analysis ("CPSM") and Residual
Profit Split Method ("RPSM") furnished by the Appellant ... purposes of
determining routine return for application of Residual Profit Split Method
("RPSM"); and
5.11 determining the weightage of split for application
method prescribed therein. The TPO
has not followed any of the prescribed method, i.e. CUP, Transaction Net
Margin Method, Resale Price Method, Profit Split ... using prescribed method such as
(CUP)comparable uncontrolled price method, transaction net margin method
(TNMM), resale price method (RPM) or profit split method
approach of benchmarking the
alleged international transaction of AMP spend using profit split method. The
Assessee vide submissions dated December 29, 2020 and December ... substantive basis by applying Residual Profit Split Method ("RPSM") which is
extension of BLT for the purpose of benchmarking, the AMP expense incurred
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
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
resident company as decided through the use
of the Profit Split Method. As discussed above, the disposal test is
satisfied in the instant case
prescribe, namely :--
(a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method ... Page 18 of 34
Signing Date:21.01.2025
16:58:28
(d) profit split method, which may be applicable mainly in
international transactions or specified domestic
