Budget 2013: Recognise the use of inter-quartile range to determine ALP, demands OPPI
OPPI suggests that instead, the regulations should prescribe for the use of inter-quartile range, which would be a better representative of the industry scenario.
OPPI says, "Section 92C(2) of the Act recognises arithmetic mean of the comparables as the Arm’s Length Price for the international transaction entered into with Associated Enterprises."
"The use of arithmetic mean tends to skew the comparable set in favour of high margin comparables", it added.
Hence, OPPI suggests that instead, the regulations should prescribe for the use of inter-quartile range, which would be a better representative of the industry scenario.
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