method adopted by the Assessee, it had not followed any particular method in making the ALP adjustment. Thirdly, the TPO held that the rate of commission on indenting transaction was determined in reference to the value of goods and not on the basis of any cost incurred by the Assessee. LIC office, gandhi nagar, nanded-431605 proprietorship collection agency vikas motilal jaiswal May-11 shri saptashringi enterprises panipat madhya pradesh IST floor kisan bhawan shop NO 40 near shiva complex assand road, panipat proprietorship collection agency rajesh kumar May-11 perfect financial services gujarat surat 102 - A,jalaram. Housing Board Haryana, Panchkula, Haryana, broadcast Engineering Consultants India Limited, Multi Location, Multi State. The questions of law framed in these appeals are also identical and read as under: 1) Whether the Income tax Appellate Tribunal was right in applying and computing arms length price with associated enterprise on indenting transactions by applying average rate of commission with non-associated. In his earlier he was responsible for managing 8 debt funds with primary responsibility on Govt. The Assessee contended that the TPO/DRP had erred in disregarding the transfer pricing approach adopted by the Assessee for determining the ALP of its international transactions. Between 19, Anup also managed different cryptocurrency trading platform reviews an offshore fund, the Merrill Lynch India Fund which was registered in Mauritius and sold to Merrill Lynch's clientele outside India. Proprietorship debt servicing venkat May-13 MAA bhagwati associates madhya pradesh hoshangabad ganeshganj, itwara bazaar, hoshangabad, madhya pradesh.
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Anoop bhaskar, head- Equity at UTI AMC,. Proprietorship, vikas sahyogi - business sourcing. As is apparent, Berry ratio has limited applicability; it can be used effectively only in cases where the value of goods have no role to play in the profits earned by an Assessee and the profits earned are directly linked with the operating expenditure incurred. The Assessee has seven operating divisions and deals in various products. This is plainly erroneous. The Assessee further claimed that the TPO had "erred in comparing indent based transactions of AEs with principal based transactions of Non- AEs and not with indent transaction of Non-AE apakah trading forex itu judi after allowing appropriate adjustments" and, therefore, the addition was misconceived, misplaced and unsustainable. He has 16 years of rich experience spread over Equity Research Fund Management. 16th Floor, Tower-A, DLF Building, Nos. Maneesh joined Team bslamc in 2006 from Pioneer Investcorp, an integrated financial services company where he led their Fixed Income consultancy and Merchant Banking division. The rate of commission in respect of transactions with Non-AEs) be taken as the bench mark for determining the ALP for commission earned in the AE segment. He started his career at Deutsche Bank in Mumbai. Vibhu bakhru, J ralidhar, J july 22, 2016 MK/RK ITA 381/2013 Connected Matters Page 32.