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Notification on Range and Multiple year Data- Flowchart

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Ajit Jain

Govt has announced final rules on range and multiple year data. I have explained the provisions by way of flow-charts.

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[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

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Notification on Range and Multiple year Data- Flowchart

  • 1. [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
  • 2. [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
  • 3. [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