![[The views/facts expresses are totally personal] By: Ajit Kumar Jain
Notification on Range – Applicable after 1 April 2014
I. Use of data
No
Yes
No
Yes
No
Yes
RPM or CPM or
TNMM Methods
Old provision for
use of data
Current year data
is available
Data to be used for
immediately two financial
years. Current year data can
be added at the time of
assessment
Current year data
is comparable to
preceding two
financial years
Comparable to be
excluded
Arm’s length computation for
the current year based on the
methods (CPM or RMP or
TMM) considered in preceding
two financial years](https://image.slidesharecdn.com/rangenotification-flowchart-151023180745-lva1-app6892/85/Notification-on-Range-and-Multiple-year-Data-Flowchart-1-320.jpg)
![[The views/facts expresses are totally personal] By: Ajit Kumar Jain
II. Applicability of Range
No
Yes
No
No
RPM or CPM or
TNMM Methods
No range
applicability. 3%
benefit
Comparable
companies > 6
No range
applicability. 3%
benefit
Computation of range
based on 35th
to 65th
percentile of data set
Transaction pricing
falling with the range
Median of
dataset is ALP
The transaction price
is at ALP](https://image.slidesharecdn.com/rangenotification-flowchart-151023180745-lva1-app6892/85/Notification-on-Range-and-Multiple-year-Data-Flowchart-2-320.jpg)
![[The views/facts expresses are totally personal] By: Ajit Kumar Jain
III. At the time of Assessment
No
Yes
Yes
No
No
Yes
No
Current year data
already available
in TP study
Current year data
is available in
public domain
TP study
comparable > 6
Refer to old
provision
New provisions
benefit of range
Continue with
preceding two
years data
Current year data
passes
quantitative and
qualitative filter
Comparable
rejected
Comparable to be
added in set](https://image.slidesharecdn.com/rangenotification-flowchart-151023180745-lva1-app6892/85/Notification-on-Range-and-Multiple-year-Data-Flowchart-3-320.jpg)
Notification on Range and Multiple year Data- Flowchart
- 1. [The views/facts expresses are totally personal] By: Ajit Kumar Jain Notification on Range – Applicable after 1 April 2014 I. Use of data No Yes No Yes No Yes RPM or CPM or TNMM Methods Old provision for use of data Current year data is available Data to be used for immediately two financial years. Current year data can be added at the time of assessment Current year data is comparable to preceding two financial years Comparable to be excluded Arm’s length computation for the current year based on the methods (CPM or RMP or TMM) considered in preceding two financial years
- 2. [The views/facts expresses are totally personal] By: Ajit Kumar Jain II. Applicability of Range No Yes No No RPM or CPM or TNMM Methods No range applicability. 3% benefit Comparable companies > 6 No range applicability. 3% benefit Computation of range based on 35th to 65th percentile of data set Transaction pricing falling with the range Median of dataset is ALP The transaction price is at ALP
- 3. [The views/facts expresses are totally personal] By: Ajit Kumar Jain III. At the time of Assessment No Yes Yes No No Yes No Current year data already available in TP study Current year data is available in public domain TP study comparable > 6 Refer to old provision New provisions benefit of range Continue with preceding two years data Current year data passes quantitative and qualitative filter Comparable rejected Comparable to be added in set