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Showing contexts for: Profit Split Method in Convergys Customer Management Group ... vs Assessee on 28 January, 2015Matching Fragments
E. The assessee has submitted that it does not prepare India specific accounts, therefore the attribution of profits on the basis as disclosed in the transfer pricing study for assets and software cannot be accepted. Further, in the facts and circumstances of the case Profit Split method is ITA 3605/Del/2013 AY: 2007-08 M/s Convergys Customer Management Group Inc. not the correct method for attribution of profits to the PE of the assessee in India.