calculated at 17.44% whereas
OP/TC has been calculated of comparables at 13.18% from software
development services. In case of (d) & (e), the assessee ... Teledata Marin Solutions Ltd. C-Seg 2.86%
Mean 13.18%
6006 & 6751/Del./2014 16
Median 12.97%
Upper Quartile 21.38%
Lower Quartile 4.24%
The details
M/S Vodafone East Limited (Formerly ... vs Acit, Cir-7, Kolkata, Kolkata on 15 December
Sabic Research & Technologies Ltd.,, ... vs Income Tax Officer,Ward-4(2),, Baroda on 1
Persistent Systems & Solutions Ltd 11.74
11. R S Software (India) Ltd 13.18
12. Sasken Communication Technologies Ltd 27.68
13. Tata Elxsi
against margin of comparables
as per the TP study report at 13.18% and hence, the assessee claimed that the
same were
13.18 A bare perusal of the above cited table
indicates that the pay band-3 of Rs.15,600-39100
with grade
preceding year marking decline of Rs. 5391/- per
transformer i.e. 13.18% over the preceding year.
The assessee did not deny the fall ... substaintial decline in selling price of
Rs. 5391/- per transformer being 13.18% over the preceding year has
not been disputed
assessee adopted multiple year data
for computing OP/TC of comparables at 13.18%. A reference was made
to TPO u/s. 92CA
years. The relevant
rule in this case of the petitioner is Rule 13.18 which is
reproduced hereunder:-
"13.18. All police officers promoted in rank
Bhangdiya and Ss 54.82% 129.92% 13.18%
PATIL JV
M/S K M Bhangdiya JV 25.28% 39.52%
Mitcon Infra Project F Ltd _ 10.07% 10.00% 10.00%
Consolidated
