CBDT withdraws circular no. 2 on Profit Split Method (PSM) and amends Circular No. 3 on Development centres
CBDT withdraws circular no. 2 on Profit Split Method (PSM), says circular appeared to give impression that PSM was most preferred method in cases involving unique intangibles; Amends Circular no. 3 to clarify meaning of phrases such as ‘economically significant functions’ and ‘low or no tax jurisdiction’; Rescission of circular No.2 and amendment and reissue of circular No.3 will clear all ambiguities; Safe Harbour rules under consideration, to be issued shortly; Circular No. 3 replaced by new Circular No. 6 CBDT Press Release Revised Circular No. 3 of 2013 and circular No. 2 of 2013 on PSM