Tag: Mean

TPG2022 Chapter III paragraph 3.62

In determining this point, where the range comprises results of relatively equal and high reliability, it could be argued that any point in the range satisfies the arm’s length principle. Where comparability defects remain as discussed at paragraph 3.57, it may be appropriate to use measures of central tendency to determine this point (for instance the median, the mean or weighted averages, etc., depending on the specific characteristics of the data set), in order to minimise the risk of error due to unknown or unquantifiable remaining comparability defects ... Read more

TPG2017 Chapter III paragraph 3.62

In determining this point, where the range comprises results of relatively equal and high reliability, it could be argued that any point in the range satisfies the arm’s length principle. Where comparability defects remain as discussed at paragraph 3.57, it may be appropriate to use measures of central tendency to determine this point (for instance the median, the mean or weighted averages, etc., depending on the specific characteristics of the data set), in order to minimise the risk of error due to unknown or unquantifiable remaining comparability defects ... Read more
India vs. Adaptec (India) P. Ltd., March 2015, Income Tax Appellate Tribunal, ITA.No. 206/Hyd/2014

India vs. Adaptec (India) P. Ltd., March 2015, Income Tax Appellate Tribunal, ITA.No. 206/Hyd/2014

Adaptec. Ltd. is engaged in the business of software, design and development and testing in the field of storage solutions. It filed its tax return declaring income of Rs.89,51,330. Since assessee is functioning as service provider to it’s group parent on cost + 10% margin basis. Following an audit, the tax authorities selected 17 comparable companies, and arrived at an arithmetic mean of 25.26% and issued an assessment of additional taxable income of Rs.63,53,365. Adaptec filed an appeal with the Income Tax Appellate Tribunal. Judgement of the Court The Court ruled predominantly in favour of the tax authorities but remanded the case for recalculations. India vs Adaptec_India_P_Ltd 206-Hyd-2014 ... Read more