Withdrawal of Circulars No. 2 dated 26th March, 2013
Circular No. 05/2013 [F. No. 500/139/2012-FTD-I], dated 29-06-2013
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.
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.
(Batsala Jha Yadav)
Director to the Government of India
Central Board of Direct Taxes
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