ARMS LENGTH PRICE - TP PROVISIONS

[raoanant]

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.