92 e report
This query is : Resolved
23 November 2015
Which Method Should be Selected to Determine ALP of Partner Remuneration(calculated as per sec 40b) for Reporting in From 3CEB please reponse early
Guest
Guest
(Expert)
23 November 2015
any other method as prescribed
23 November 2015
thank u for ur response how you selected this method please provide me basis for Selection this method
Guest
Guest
(Expert)
23 November 2015
Sure.
The new method inserted by way of Rule 10AB states that “any method which takes
into account the price which has been charged or paid, or would have been charged
or paid, for the same or similar uncontrolled transaction, with or between nonassociated
enterprises, under similar circumstances, considering all relevant facts”,
The other 5 methods can't be applied as they are very specific The sixth method introduced by the CBDT does not provide either clarity or
guidance in terms of the manner of benchmarking a transaction under this method.
Though it appears that the Rule would provide more flexibility to the taxpayer for
determination of the arm’s length price, it needs to be noted that this flexibility will
also be available to the Revenue authorities, and could be used to undertake
aggressive adjustments resulting in further litigation.
The new method inserted by way of Rule 10AB states that “any method which takes
into account the price which has been charged or paid, or would have been charged
or paid, for the same or similar uncontrolled transaction, with or between nonassociated
enterprises, under similar circumstances, considering all relevant facts”,
The other 5 methods can't be applied as they are very specific The sixth method introduced by the CBDT does not provide either clarity or
guidance in terms of the manner of benchmarking a transaction under this method.
Though it appears that the Rule would provide more flexibility to the taxpayer for
determination of the arm’s length price, it needs to be noted that this flexibility will
also be available to the Revenue authorities, and could be used to undertake
aggressive adjustments resulting in further litigation.
Guest
Guest
(Expert)
23 November 2015
Dont worry go for that even i did the same when i filed the 3ceb.
Message likes :
1 times
23 November 2015
THANK U SO MUCH SIR :)
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