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31. He has contended that on page 16 of assessment order, the assessing officer observed that in respect of Intermediates transferred out of Kurkumbh, the same were not sold by the assessee and therefore there was no market available for determining the market related rates. In this regard he has contended that as per section 80-IA(9) read with Explanation thereto what is relevant is not actual sale by the assessee, but the assumption of a hypothetical market and a hypothetical price. Reliance was placed on the decision of the Bombay High Court in the case of CWT v. Purshottam N. Amersey (1969) 71 ITR 180 (Bom). He has contended that section 80-IA(9) requires the computation of the profits on commercial accounting principles as if the undertaking is the only source of income. Reliance was placed on the decision of the Supreme Court in the case of Tata Iron & Steel Co. Ltd. v. State of Bihar (1963) 48 ITR 123 (SC), for the proposition that though the profits are made or received at the ultimate point of sale of the final output but the profits are earned or derived in a distributive sense which are required to be telescoped in all the activities of the enterprise which finally culminate into the receipt of profits at the last stage. He has contended that the assessee has adopted the well known commercial accounting principle of Profits split method by deriving the transfer price from the sale price of the final bulk drug which is produced out of the Intermediates transferred from Kurkumbh. For the method of working he has referred to Annexure 'C' to the order of Commissioner (Appeals).