Transfer pricing – Operating profit of different STP units rendering identical services to related parties should not be considered on a stand-alone basis for computing ALP

ACIT v Birla Soft Ltd. ITAT, Delhi ITA No. 4001 (Delhi) of 2009 Assessment Year: 2004-05 Decided on: 17 June 2011 Order Rajpal Yadav, JM 1. The revenue is in appeal before us against the order of Learned CIT (Appeals) dated 28-7-2009 passed for the assessment year 2004-05. In the first ground of appeal, revenue has pleaded that Learned CIT (Appeals) has erred in deleting the additions made by the Assessing Officer on the recommendations made by the learned TPO for adjustment in arm’s length price on the international transactions carried out by the assessee with its asso...