TIOL-DDT 2138 · Monday, 1 July 2013 · story 3 of 7

CBDT rescinds Circular No. 2 on application of Profit Split Method

CBDT has noticed that Circular No. 2/2013 dated 26.3.2013 regarding application of Profit Split Method 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.

Now, CBDT has withdrawn the Circular No. 2 with immediate effect.

CBDT Circular No. 5/2013, Dated: June 29, 2013