notification on range and multiple year data- flowchart
TRANSCRIPT
[The views/facts expresses are totally personal] By: Ajit Kumar Jain
Notification on Range – Applicable after 1 April 2014
I. Use of data
No
Yes
No
Yes
No
Yes
RPM or CPM or
TNMM Methods
Old provision for
use of data
Current year data
is available
Data to be used for
immediately two financial
years. Current year data can
be added at the time of
assessment
Current year data
is comparable to
preceding two
financial years
Comparable to be
excluded
Arm’s length computation for
the current year based on the
methods (CPM or RMP or
TMM) considered in preceding
two financial years
[The views/facts expresses are totally personal] By: Ajit Kumar Jain
II. Applicability of Range
No
Yes
No
No
RPM or CPM or
TNMM Methods
No range
applicability. 3%
benefit
Comparable
companies > 6
No range
applicability. 3%
benefit
Computation of range
based on 35th to 65th
percentile of data set
Transaction pricing
falling with the range
Median of
dataset is ALP
The transaction price
is at ALP
[The views/facts expresses are totally personal] By: Ajit Kumar Jain
III. At the time of Assessment
No
Yes
Yes
No
No
Yes
No
Current year data
already available
in TP study
Current year data
is available in
public domain
TP study
comparable > 6
Refer to old
provision
New provisions
benefit of range
Continue with
preceding two
years data
Current year data
passes
quantitative and
qualitative filter
Comparable
rejected
Comparable to be
added in set