Held that segmental profitability as determined by assessee was correct as per which OP/OC from services to AE at 18.04 per cent was better than OP/OC from non-AE services at 13.44 per cent showing international transaction at ALP. Adjustment made was deleted. (AY. 2016-17)
Neilsoft (P) Ltd. v. Dy. CIT (2022) 209 DTR 225/ 215 TTJ 545 / 136 taxmann.com 66 (Pune) (Trib)
S. 92C : Transfer pricing-Arm’s length price-Engineering design services-Separate segmental accounts-Adjustment made by TPO was deleted. [S. 92CA]