Allowing the appeal, the Revenue had not controverted the assessee’s contentions that its margin was 23.3 per cent. in the software development segment as compared to 11.42 per cent. of the comparable companies and that the assessee had already made requisite working capital adjustment to factor in the impact of delayed receivables. Moreover, an identical issue stood settled in favour of the assessee in its own case for the assessment year 2010-11 and no distinguishing features had been pointed out by the Revenue. Further, the Revenue had also not brought on record any material to show that this decision had been set aside or stayed or overruled by the higher judicial forum. The Revenue was not justified in making the addition. (AY. 2011-12)