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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)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2012-13
Advertisement 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...
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Author Info

CA Saurabh Jadhav
Qualification: CA in Job / Business
Company: Amazon
Location: Pune, Maharashtra
Articles Published: 30

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