Pricing
wherein it is provided that although broader product
differences can be allowed in the resale price method, the
property transferred ... standard methods. In any event,
any preference of one method over the other
method must be justified by the Transfer Pricing
method as the most appropriate transfer pricing method, although
the said method applied is not in accordance with the first proviso ... method as the most appropriate transfer pricing method, although
the said method applied is not in accordance with the first proviso
rejecting Transactional
Net Margin Method ("TNMM") selected by the Appellant in its
transfer pricing study report for benchmarking ... application of most appropriate transfer pricing
method and arm's length price of these transactions have already
been
methods:
(a) Comparable Uncontrolled Price Method (CUPM)
(b) Resale Price Method (RPM)
(c) Cost Plus Method (CPM)
(d) Profit Split Method ... following methods, being the most
appropriate method, in the following manner,
namely: -
(a) comparable uncontrolled price method, by
which, -
(i) the price
Pricing Officer for determination of arm's length price of the
above transactions. According to the transfer pricing ... margin method [TNMM] as most appropriate method for
determination of arms length price selecting 19 comparables,
The Ld. Transfer Pricing
matches with
the comparables would result in affirmation of the transfer price
as the arm's length price ... length
price for the right to use. The arm's length price would be the fair
market price
with other transactions adopting TNMM as the most
appropriate method. The Transfer Pricing Officer has rejected the
benchmarking of the assessee ... Uncontrolled Price Method;
ii) Resale Price Method;
iii) Cost Plus Method;
iv) Profit Split Method;
v) Transactional Net Margin Method
computation of Arm's length price of International transactions to Transfer Pricing Officer (TPO). The TPO accepted that ... such differences. As with the resale price and cost plus methods that the transactional net margin method resembles, this, however, does not mean
Escorts Ltd. And Another vs Union Of India And Others on 9 November, 1984
Equivalent
Uncontrolled Price Method;
b)Resale Price Method;
c)Cost Plus Method;
d)Profit Split Method;
e)Transactional Net Margin Method ... Method has seen a transition from a dis
favoured comparabe method, to possibly the most appropriate
Transfer Pricing method
