Residual Profit Split Method, once accepted and computed for an...

Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.