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Use Of Berry Ratio As PLI Upheld

Published on Mon, Aug 03,2015 | 15:18, Updated at Mon, Aug 03 at 15:18Source : 

In a recent ruling, the Delhi Bench of the Income-tax Appellate Tribunal, placing extensive reliance on the ruling made by the same bench in the case of Mitsubishi Corporation India Private Limited, has
• Upheld the use of the ‘Berry ratio’ as profit level indicator (PLI).
• Rejected the transfer pricing officer’s (TPO’s) re-characterisation of the taxpayer’s service activity to a trading activity.
• Rejected the TPO’s contentions pertaining to attribution of additional returns on account of location savings and certain supply chain and human intangibles owned/ developed by the taxpayer
This PWC alert details the case and the order
Attachments : Marubeni-Itochu-Steel-Transfer Pricing - Berry ratio - PWC Alert.pdf

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