revenue split. During the year under assessment,
assessee company entered into international transaction as under:-
Nature of transaction Method Value
1 Provision of Software Development ... provision of software development services adopted TNMM as
the most appropriate method and computed the test party margin at
6 ITA No.6464/Del./2012
2016 & CO 1304/Mum/2015
KBL PIL Consortium
project and not splitting Income in the hands of its
member before arriving the income ... case of contractor working of profit. has to be taken
as per percentage completion method for the reason that
there is certainty of revenue which
accepted the stand of the assessee's
allocation method based on the SAP system in the subsequent AY.s.i.e.2007 ... given a proper reconciliation to the
TPO of the profit as per the segmental financial split and the profit as per
audited financials which clearly
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Equivalent
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Mirza Ghalib T. T. College & Ors vs The State Of Bihar & Ors on
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Author
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Author: S. Muralidhar