Which tp method be used

Dipjyoti Majumdar (CA in service & CS. dipmaj@ rediffmail.com )   (3468 Points)

10 January 2012  

I invite your opinion on which TP method to be used for arm's length pricing determination in the undernoted circumstances:

Facts : 1) In the FY  there are only international transactions with Foreign Related Parties. Therefore there is no internal CUP.

TNMM method cannot be used, possibly as there is loss from main activity/core operations though there is net profit (due to other income). 3) Profit split; resale price; method are not applicable , I guess.

Regards,