All areas of taxation : Personal Tax, Corporate Tax. | Suggesting legal structure of business entities. | Transactional advisory - optimal deal structure | T
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SECTION 92C OF THE INCOME-TAX ACT, 1961 - READ WITH RULE 10B OF THE INCOME-TAX RULES, 1962 - TRANSFER PRICING - COMPUTION OF ARM'S LENGTH PRICE - APPLICATION OF PROFIT SPLIT METHOD - WITHDRAWAL OF CIRCULAR NO. 2/2013, DATED 26-3-2013 CIRCULAR NO. 5/2013 [F. NO. 500/139/2012-FTD-I], DATED 29-6-2013 The Central Board of Direct Taxes had issued Circular No. 2 (hereinafter called "the Circular") on 26th March 2013 regarding application of Profit Split Method. 2. It is noticed the Circular appeared to give the impression that there was a hierarchy among the six method listed in section 92C and that Profit Split Method (PSM) was the preferred method in the case involving unique intangible or in multiple interrelated international transactions. 3. Accordingly, the Central Board of Direct Taxes withdraws Circular No 2 dated 26th March 2013 with immediate effect. The above may be brought to the notice of all concerned. |
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