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Showing contexts for: Profit Split Method in Dongfang Electric Corporation, ... vs Ddit (It)-1(1), Kolkata, Kolkata on 25 October, 2017Matching Fragments
4. Without prejudice to the above grounds, the adjustment of Rs 236,541,345 made by the Assessing Officer/TPO/DRP vide impugned order is bad in law and on the facts and circumstances of the case as the same has been made:-
(i) By applying Transactional Net Margin Method and rejecting Comparable Uncontrolled Price method or Profit Split Method for determining the amount of profit;8
I.T.A. No. 572/Kol/2014 Assessment Year: 2009-10 & I.T.A. No. 487/Kol/2015 Assessment Year: 2010-11 Dongfang Electric Corporation
9. Without prejudice to the above grounds, the adjustment of Rs. 54,693,572 made by the AO/ TPO/ DRP vide impugned order is bad in law and on the facts and circumstances of the case as the same has been made:-
(i) By applying Transactional Net Margin Method and rejecting Comparable Uncontrolled Price method or Profit Split Method for determining the amount of profit;11
I.T.A. No. 572/Kol/2014 Assessment Year: 2009-10 & I.T.A. No. 487/Kol/2015 Assessment Year: 2010-11 Dongfang Electric Corporation