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2010 (1) TMI 806 - AT - Income TaxArm's length price of the international transaction - assessee filed a audited report in Form No. 3CEB, and adopted CUP method for computing the arm's length price - PO on the ground that, the assessee has not given any comparables, had rejected the method - whether TNM Method allows the Assessing Officer to take the profits at enterprises level - Held that:- section 92C read with rule 10B(1)(e) deals with Transactions Net Margin Method (TNMM) and it refers to only net profit margin realised by an enterprise from an international transaction or a class of such transaction, but not operational margins of enterprises as a whole, TPO as well as the Assessing Officer have committed an error by wrongly applying Transaction Net Margin Method. appeal of the Revenue is dismissed.
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