https://www.taxtmi.com/circulars?id=12122 PSM is suited for transfer of unique intangibles or interrelated transactions and allocates returns based on relative contributions; cost based methods tied to R&D costs are generally discouraged. Application of PSM depends on transaction nature, functions, assets, risks, and critically on availability, coverage and reliability of data. If a Transfer Pricing Officer concludes PSM cannot be applied due to data deficiencies, the officer must record reasons for non applicability before considering TNMM or CUP, and taxpayers are required to maintain prescribed documentation, so lack of information requires good and sufficient reason. en-us Tue, 26 Mar 2013 00:00:00 +0530 Fri, 29 Mar 2013 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=12122 PSM is suited for transfer of unique intangibles or interrelated transactions and allocates returns based on relative contributions; cost based methods tied to R&D costs are generally discouraged. Application of PSM depends on transaction nature, functions, assets, risks, and critically on availability, coverage and reliability of data. If a Transfer Pricing Officer concludes PSM cannot be applied due to data deficiencies, the officer must record reasons for non applicability before considering TNMM or CUP, and taxpayers are required to maintain prescribed documentation, so lack of information requires good and sufficient reason. Circulars Income Tax Tue, 26 Mar 2013 00:00:00 +0530 https://www.taxtmi.com/circulars?id=12122