Transfer pricing query

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Mohit Kavadia (Querist)

17 November 2014 Dear All, Good Morning,

I have a query for Transfer Pricing Report namely 3CEB...

In my case i have to file Transfer Pricing Report of X Ltd. and it is having and associated enterprise in Italy namely Y Ltd.

X Ltd. is Purchasing goods from Y Ltd. and also selling goods to Y Ltd.

Kindly suggest which method should be used for determining the arm's length price?

And which method is used when, how it can be known?

Kindly do needful in this regards.
Thanks & Regards,

Amol S Joglekar

Amol S Joglekar (Expert)

17 November 2014 Cost plus method be used.

Mohit Kavadia

Mohit Kavadia (Querist)

17 November 2014 Thanks Amolji for your kind reply. I would also like to know that how Cost Plus Method triggers in this case?

In this connection, if possible will u inform me that which methods can be used in which circumstances.?

Soliciting your esteemed co-operation in it.

Thanks & Regards,

Amol S Joglekar

Amol S Joglekar (Expert)

18 November 2014 (a) comparable uncontrolled price method;
(b) resale price method;
(c) cost plus method;
(d) profit split method;
(e) transactional net margin method;
(f) such other method as may be prescribed89 by the Board.
These are the various methods embeddedin section 92C of the Income Tax Act.
In majority of the cases a judgemental call needs to be taken as to which method is most suitable to find out the arm's length price.

Mohit Kavadia

Mohit Kavadia (Querist)

18 November 2014 Thanks Amolji for your kind reply... :)

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