Profit Split Method Rejected for Transfer Pricing; TPO to Use Residual PSM for Arm's Length Price Determination.

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....TP Adjustments - Disregarding Profit Split Method ('PSM') as the most appropriate method for benchmarking - TPO, should determine the ALP by adopting residual PSM as the MAM and by allocating residual profits based on the relative value of each enterprise's contribution - AT....