Use Of Berry Ratio As PLI Upheld
Published on Mon, Aug 03,2015 | 15:18, Updated at Mon, Aug 03 at 15:18Source : Moneycontrol.com
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• 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
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