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TNMM vs “Other Method” & Validity of Berry Ratio under Limited Risk Model: ITAT Delhi in Verizon India Case
Case Law Details
- Case Name
- Verizon Communications India P. Ltd. Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Delhi
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Verizon Communications India P. Ltd. Vs ACIT (ITAT Delhi)
TNMM vs “Other Method” & Validity of Berry Ratio under Limited Risk Model: ITAT Delhi in Verizon India Case
Introduction
The Delhi ITAT’s ruling in Verizon Communications India Pvt. Ltd. (AY 2012-13) provides a nuanced and practically significant exposition on transfer pricing jurisprudence, particularly in the context of selection of the Most Appropriate Method (MAM), validity of Limited Risk Models (LRM), and the implicit recognition of cost-based profit level indicators akin to the Berry Ratio. In an era wh...




