Method adopted by Assessee for determining ALP cannot be rejected without showing fallacies in method adopted by Assessee

IN THE ITAT MUMBAI BENCH ‘J’ Assistant Commissioner of Income-tax Versus Sonata Software Ltd. IT APPEAL NO. 3514 (MUM.) OF 2010 [ASSESSMENT YEAR 2005-06] AUGUST 29, 2012 ORDER N.K. Billaiya, Accountant Member This appeal by the Revenue is directed against the order of Ld. CIT(A)-15 Mumbai dt.12.2.2010 for assessment year 2005-06. 2. The Revenue has raised following substantive grounds of appeal: “1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in holding that the assessee is eligible for deduction u/s. 10A of the I.T...