Transfer Pricing – Benchmark cannot be applied on a global basis but has to be on a transaction basis ; Tribual explains Important Principles of Cost Plus, CUP and TNMM

ACIT Vs Tara Ultimo Private Limited (ITAT Mumbai)- The application of Cost Plus Method thus provides for (i) ascertaining the direct and indirect costs of property transferred, or services rendered, to the associated enterprises; (ii) ascertaining the normal mark up of profit over aggregate of direct costs and indirect costs in respect of same or similar property or services, or a series of transactions of same or similar property or services, to the unrelated enterprises; (iii) adjusting the normal mark up, or gross profit, for differences, if any, in the material factors (to give simple exa...