Determination of ALP- TNM Method requires comparison of net profit margins and not operating margins of enterprises

 ITAT MUMBAI BENCH `L’ MUMBAI, IN THE CASE OF: ACIT Vs. Wockhardt Ltd., APPEAL NO: ITA No. 3556/Mum/ 2007, DECIDED ON July 9, 2010 ORDER PER R S PADVEKAR: In this appeal, the revenue has challenged the impugned order of the ld CIT (A), Central-III, Mumbai for the assessment year 2004-5 dated 7.2.2007. 2 The first issue is in respect of dis allowance of the payment made to clubs of Rs.18.14 lacs. 2.1 The assessee is in the business of manufacturing and trading of pharmaceuticals products. The return of income filed by the assessee was selected for scrutiny and the assess...