A SOFTWARE COMPANY EARNED NET PROFIT OF ABOUT 50 % DEPENDING UPON THE NATURE OF TRANSACTIONS AND THE OPPORTUNITIES PROVIDED BY MARKET DURING 2-3 YEARS. THE ARMS LENGTH PROFIT IS ABOUT 15 %. WHETHER AO CAN RESTRICT THE PROFIT TO 20 % ? THE CIT(A) HAS PASSED AN ORDER IN FAVOUR OF THE ASSESSEE. ANY DIRECT CASE LAWS AS THE CASE IS IN ITAT ON DEPT. APPEAL.