considered while determining L1 bidders.
To identify outliers, a combination of Quartile method and Deviation from Average
will be used. The quartile method will provide ... clause, at first, prescribes the use of a statistical technique called Inter
Quartile Range ["IQR"] method, which employs QUARTILE.INC function,
to define
have rejected companies which were lying outside the inter-quartile range of SG&A expenses/Sales of the 242 comparable companies.
-Net Profit ... Rejecting
companies with SG&A Expenses/ Sales falling outside the inter-quartile
range
98
Rejecting
companies with Net Profit 0
Qualitative
Review to match
deprived
district, i.e. one which falls within the first and second quartile, using
various enumerated parameters. The list of districts within quartile ... quartile 2 has also been given in the Information Brochure. The petitioner
completed her Class X and Class XII from District Alwar in the State
done in a statistical manner, such as by taking the inter-quartile range
of the comparables set. The ld DR has submitted that this approach ... concept of
inter-quartile range, does not find place in the Indian law; but this aspect is in the US
law because under the provisions
comparables - 15-28%, Weston India - 23.48%.
ix) Assessee relied upon inter-quartile range - lower
quartile - 6%; Upper Quartile - 36% - refer page ... report and table 9 Quartile range as submitted by the
assessee.
x)Data of comparable companies used in the TP report
pertains
OECD guidelines, on the other
hand, have enunciated the principle of quartile method for calculation of ALP,
wherein the comparables that fall in the extreme ... quartiles get excluded and the
middle quartiles are considered for benchmarking the transactions. The approach of
the TPO by selecting the band of PLI between
OECD guidelines and the US TP regulations
because they advocate the quartile method for determining ALP under
which companies that fall in the extreme quartiles ... excluded and only
those that fall in'the middle quartiles are reckoned for comparability.
Cases of either abnormal profits or losses (referred
this
aspect and specify the Arithmetic Mean for
determining ALP. In the Quartile Method,
the companies that fall in the extreme
quartiles get excluded ... only those that
fall in the middle quartile are retained for
comparability thereby automatically
eliminating outlines whereas in the
Arithmetic Mean Method all companies that
Haldor Topsoe (I) Pvt Ltd, New Delhi vs Dcit, New Delhi on 26 December, 2018
this aspect and
specify the Arithmetic Mean for determining ALP. In the Quartile Method, the companies that
fall in the extreme quartiles get excluded ... only those that fall in the middle quartile are
retained for comparability thereby automatically eliminating outliners whereas in the Arithmetic
Mean Method all companies that