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Showing contexts for: Profit Split Method in Smart Cube India Pvt. Ltd., Noida vs Acit, New Delhi on 29 July, 2020Matching Fragments
2.11 That on the facts and circumstances of the case the DRP/TPO erred in not appreciating that the international transaction of rendering IT enabled services are established to be at ALP applying Profit Split Method as the most appropriate method and no adjustment on account of the alleged difference in arm's length price would be warranted.
Corporate tax addition
3. That the assessing officer / DRP erred on facts and in law denying deduction of Rs.1,82,35,728/- claimed by the applicant under section 10B of the Act.