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“most appropriate method”

Transfer PricingSection 92CSection 92C1,345 judgments

The decision most relied on for most appropriate method is CIT v. Cushman & Wakefield (India) (P.) Ltd. (367 ITR 730), cited in 120 judgments on BharatTax.

Leading authorities on most appropriate method

CIT v. Cushman & Wakefield (India) (P.) Ltd.
367 ITR 730 · 2014 · High Court
120
citing judgments

This case determines the Arm's Length Price (ALP) for intra-group services and reimbursements, clarifying when charges constitute services warranting a mark-up versus mere pass-through costs. It provides guidance on the circumstances under which an ALP adjustment, including an ALP of 'nil', is appropriate for such transactions.

Dresser-Rand India (P.) Ltd. v. Addl. CIT
13 Taxmann.com 82 · 2011 · High Court
43
citing judgments

An Assessing Officer cannot disregard an assessee's decision to avail services from associated enterprises, even if the assessee has internal expertise, as the determination of necessity is the assessee's prerogative. The Transfer Pricing Officer's role is to determine the arm's length price, not the need for the service itself.

CIT v. EHPT India P Ltd.
350 ITR 41 · 2013 · High Court
41
citing judgments

The headcount method is an appropriate allocation key for indirect expenses between eligible and non-eligible units when it has been consistently accepted by revenue authorities and there is no just cause for abandoning it. Deviation from a consistently followed and accepted method can disturb or distort profits.

Mobis India Ltd. v. Dy. CIT
38 Taxmann.com 231 · 2013 · ITAT
38
citing judgments

A working capital adjustment is unreliable if it is based on broad approximations, estimations, and assumptions, and the assessee fails to demonstrate how the adjustment was arrived at.

LG Electronics India Pvt. Ltd. v. ACIT
29 Taxmann.com 300 · 2013 · High Court
37
citing judgments

The 'bright line test' is not an appropriate method for determining the existence of an international transaction for calculating arm's length price. This ruling overrules prior special bench decisions on AMP expenses.

Magneti Marelli Powertrain India Pvt. Ltd. v. DCIT
389 ITR 469 · 2016 · High Court
35
citing judgments

The Assessing Officer (AO) or Transfer Pricing Officer (TPO) cannot dispute the application of the TNMM method if they have already accepted it as the most appropriate method for certain international transactions, especially when other transactions are intrinsically linked.

Skoda Auto India (P) Ltd. v. ACIT, Aurangabad
30 SOT 319 · 2009 · ITAT
26
citing judgments

The Tribunal may allow adjustments for differences between the tested party and comparable companies to eliminate material differences, provided accurate and credible evidence is furnished.

Principal Commissioner of Income-tax-6 v. Matrix Cellular International Services (P.) Ltd.
90 Taxmann.com 54 · 2018 · High Court
25
citing judgments

The Resale Price Method (RPM) is the most appropriate method for determining the arm's length price of a distributor who does not add significant value to the goods purchased.

Judgments citing most appropriate method

Cabot India Ltd., Mumbai vs. DCIT 1(1), Mumbai

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 2108/MUM/2016[2010-11]Status: DisposedITAT Mumbai21 Aug 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

addition on account of non-reconciliation of ITS data. Both the parties submitted that with respect to the benchmarking of Royalty, the most appropriate method is required to be adjudicated and with respect to carry forward of losses and addition on account of non- reconciliation of ITS data only direction ... number 170/M/2010 has set-aside the whole issue back to the file of the learned assessing officer for determining the most appropriate method. It is important to note down the finding of the coordinate bench for assessment year 2005 – 06 at Para number 11 (page number 13). In that assessment

Asst CIT 15(1)(2), Mumbai vs. Cabot India Ltd, Navi Mumbai

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 1911/MUM/2016[2011-12]Status: DisposedITAT Mumbai21 Aug 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

addition on account of non-reconciliation of ITS data. Both the parties submitted that with respect to the benchmarking of Royalty, the most appropriate method is required to be adjudicated and with respect to carry forward of losses and addition on account of non- reconciliation of ITS data only direction ... number 170/M/2010 has set-aside the whole issue back to the file of the learned assessing officer for determining the most appropriate method. It is important to note down the finding of the coordinate bench for assessment year 2005 – 06 at Para number 11 (page number 13). In that assessment

Cabot India Ltd, Mumbai vs. DCIT 1(1), Mumbai

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 1842/MUM/2016[2006-07]Status: DisposedITAT Mumbai21 Aug 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

addition on account of non-reconciliation of ITS data. Both the parties submitted that with respect to the benchmarking of Royalty, the most appropriate method is required to be adjudicated and with respect to carry forward of losses and addition on account of non- reconciliation of ITS data only direction ... number 170/M/2010 has set-aside the whole issue back to the file of the learned assessing officer for determining the most appropriate method. It is important to note down the finding of the coordinate bench for assessment year 2005 – 06 at Para number 11 (page number 13). In that assessment

Cabot India Ltd, Mumbai vs. DCIT 1(1), Mumbai

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 6318/MUM/2014[2009-10]Status: DisposedITAT Mumbai21 Aug 2023AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

addition on account of non-reconciliation of ITS data. Both the parties submitted that with respect to the benchmarking of Royalty, the most appropriate method is required to be adjudicated and with respect to carry forward of losses and addition on account of non- reconciliation of ITS data only direction ... number 170/M/2010 has set-aside the whole issue back to the file of the learned assessing officer for determining the most appropriate method. It is important to note down the finding of the coordinate bench for assessment year 2005 – 06 at Para number 11 (page number 13). In that assessment

Cabot India Ltd, Mumbai vs. DCIT 1(1), Mumbai

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 2539/MUM/2014[2007-08]Status: DisposedITAT Mumbai21 Aug 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

addition on account of non-reconciliation of ITS data. Both the parties submitted that with respect to the benchmarking of Royalty, the most appropriate method is required to be adjudicated and with respect to carry forward of losses and addition on account of non- reconciliation of ITS data only direction ... number 170/M/2010 has set-aside the whole issue back to the file of the learned assessing officer for determining the most appropriate method. It is important to note down the finding of the coordinate bench for assessment year 2005 – 06 at Para number 11 (page number 13). In that assessment

Cabot India Ltd, Mumbai vs. Asst CIT 1(1), Mumbai

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 7496/MUM/2012[2008-09]Status: DisposedITAT Mumbai21 Aug 2023AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

addition on account of non-reconciliation of ITS data. Both the parties submitted that with respect to the benchmarking of Royalty, the most appropriate method is required to be adjudicated and with respect to carry forward of losses and addition on account of non- reconciliation of ITS data only direction ... number 170/M/2010 has set-aside the whole issue back to the file of the learned assessing officer for determining the most appropriate method. It is important to note down the finding of the coordinate bench for assessment year 2005 – 06 at Para number 11 (page number 13). In that assessment

M/S Isoft Health Management (India) Pvt. Ltd., Chennai vs. DCIT, Bangalore

In the result, appeal of assessee is allowed

ITA 1210/BANG/2011[2007-08]Status: DisposedITAT Indore21 Aug 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicomputer Sciences Dcit, Circle 11(4) Corporation India Private No. 14/3, 5Th Floor, R.P. Limited Bhawan Nrupathunga (Formerly Isoft Health Road Vs. Management (India) Pvt. Bangalore Ltd.) Unit-13, Block-2, Sdf Building Mpez Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaaco 2465N Assessee By Shri Vishal Kalra, Ar Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 03.08.2023 Date Of Pronouncement 21.08.2023

Section 143(3)Section 144C(13)Section 144C(15)(b)Section 144C(5)Section 153(1)Section 92C

price has to be determined by any one of the methods stipulated in sub-section (1) of section 92C and by applying the most appropriate method referred to in sub-section (2) thereof. There may be occasions where application of the most appropriate method provides results which are different ... various factors and so on. The selection of the most Page 7 of 15 Computer Sciences Corporation India Pvt. Ltd. Page 8 of 15 appropriate method will depend upon the facts of the case and the factors mentioned in rules contained in rule 10C. The TPO after taking into account

Thermax Babcock & Wilcox Energy Solutions P.Ltd, Mumbai vs. DCIT Cir 2(3)(1), Mumbai

In the result, appeal filed by the assessee is partly allowed as indicated above

ITA 1735/MUM/2016[2011-12]Status: DisposedITAT Mumbai18 Aug 2023AY 2011-12

prescribed methods of benchmarking are followed by the Appellant and additionally, the Appellant has not been able to establish CUP as Most Appropriate Method (MAM) in the instant case and upheld the findings of the TPO. 4.35 Needless to say, any other method or any other comparable uncontrolled price, specifically

DCIT 1(3), Mumbai vs. Rabo India Finance Ltd, Mumbai

In the result, Ground Nos

ITA 1584/MUM/2014[2006-07]Status: DisposedITAT Mumbai18 Aug 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Rahul Chaudhary, Hon'Bledcit – 1(3) V. M/S. Rabo India Finance Ltd., Room No. 564, Aayakar Bhavan Forbes Building, 1St Floor M.K. Road, Mumbai - 400020 Charanjit Rai Marg, Fort Mumbai – 400001 Pan: Aaacr6065R (Appellant) (Respondent) Assessee Represented By : Shri Nitesh Joshi Department Represented By : Shri Gaurav Batham

Section 147Section 37(1)Section 92C

agreement and ECB agreement. The same has not been disputed by the TPO  RIFL has benchmarked the transaction by applying CUP as the most appropriate method. and  The requirement of law is that the expenditure should be incurred wholly and exclusively for the purpose of business. This fact

Emerson Electric Company (India) Private Limited, Mumbai vs. Addl/Jt/Dy/Asstt/CIT/ITO, Delhi

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 555/MUM/2022[2017-18]Status: DisposedITAT Mumbai14 Aug 2023AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Dinesh Bafna a/wFor Respondent: Shri R.S. Srivastav
Section 142(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 92C

administration of server hosting and related services, etc.” 8. For benchmarking this transaction, the assessee used Transactional Net Margin Method (“TNMM”) as the most appropriate method with the Profit Level Indicator (“PLI”) of Operating Profit to Total Cost (“OP/TC”). By considering itself as the tested party, the assessee identified ... based on their requirements. Emerson Electric Company (India) Pvt. Ltd. ITA no.555/Mum./2023 For benchmarking this transaction, the assessee used TNMM as the most appropriate method with PLI of OP/TC. By considering itself as the tested party, the assessee identified five comparable companies with an average margin

Emerson Network Power (India) P.Ltd, Thane vs. Addl CIT RG 1, Thane

In the result, both the appeals of the assessee are partly allowed

ITA 2286/MUM/2017[2012-13]Status: DisposedITAT Mumbai14 Aug 2023AY 2012-13
Section 143(3)

Information Technology o Logistic o Finance 8. In its Transfer Pricing Study Report (the TPSR) the assessee benchmarked the transaction following TNMM the most appropriate method and treating AE as tested party with mark- up of 5.8%. The TPSR also provides for the types of services rendered and benefit availed ... shown by comparable companies. In such scenario, we find no merit in the order of the TPO in applying CUP method as the most appropriate method. The findings of TPO in this regard are thus reversed. Accordingly, we hold that the TNMM method is most appropriate method appropriate method

Emerson Network Power (India) Pvt. Ltd., Thane vs. DCIT Cir. 1, Thane

In the result, both the appeals of the assessee are partly allowed

ITA 2120/MUM/2016[2011-12]Status: DisposedITAT Mumbai14 Aug 2023AY 2011-12
Section 143(3)

Information Technology o Logistic o Finance 8. In its Transfer Pricing Study Report (the TPSR) the assessee benchmarked the transaction following TNMM the most appropriate method and treating AE as tested party with mark- up of 5.8%. The TPSR also provides for the types of services rendered and benefit availed ... shown by comparable companies. In such scenario, we find no merit in the order of the TPO in applying CUP method as the most appropriate method. The findings of TPO in this regard are thus reversed. Accordingly, we hold that the TNMM method is most appropriate method appropriate method

Aero Club, New Delhi vs. ACIT, Central Circle-49(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 2957/DEL/2022[2018-19]Status: DisposedITAT Delhi09 Aug 2023AY 2018-19

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Pradip Dinodia, CA &For Respondent: Sh. Rajesh Kumar, CIT DR
Section 139(1)Section 143(3)Section 270A

grossly erred in law and on facts of the assessee's case in rejecting the Other Method applied by the assessee as the Most Appropriate Method (MAM) to determine the arm's length price of the Specified Domestic Transactions entered into by the assessee without any cogent reasons. 5) That

Ahlstrom Fiber Composites (I) P. Ltd., Mundra (Kutch) vs. The Asstt. Commr. of Income Tax, Gandhidham Circle, Gandhidham

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 85/RJT/2017[2012-13]Status: DisposedITAT Rajkot04 Aug 2023AY 2012-13

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 144C(13)Section 92C

AO/TPO erred in rejecting cost plus method (CPM) adopted by the Appellant and selecting Transactional Net Margin Method (TNMM) as the most appropriate method to determine the Arm's Length Price of the transaction of sale of goods to AEs. 1.4. Without prejudice, the Ld. TPO erred in selecting certain ... rejected the segmental accounts of the assessee and also the CPM method selected as the Most Appropriate Method (MAM) for benchmarking the transactions and treating Transactional Net Margin Method (TNMM) as the MAM, he selected comparables and determined their average margin of operating profit to operating cost, OP/OC

Ahlstrom Fiber Composites (I) P. Ltd., Mundra (Kutch) vs. The Asstt. Commr. of Income Tax, Gandhidham Circle, Gandhidham

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 287/RJT/2017[2013-14]Status: DisposedITAT Rajkot04 Aug 2023AY 2013-14

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 144C(13)Section 92C

AO/TPO erred in rejecting cost plus method (CPM) adopted by the Appellant and selecting Transactional Net Margin Method (TNMM) as the most appropriate method to determine the Arm's Length Price of the transaction of sale of goods to AEs. 1.4. Without prejudice, the Ld. TPO erred in selecting certain ... rejected the segmental accounts of the assessee and also the CPM method selected as the Most Appropriate Method (MAM) for benchmarking the transactions and treating Transactional Net Margin Method (TNMM) as the MAM, he selected comparables and determined their average margin of operating profit to operating cost, OP/OC

Ahlstrom Fibercomposites India Pvt. Ltd., Mundra (Kutch) vs. The Dy. Commr. of Income Tax, Gandhidham Circle, Gandhidham

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 97/RJT/2016[2011-12]Status: DisposedITAT Rajkot04 Aug 2023AY 2011-12

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 144C(13)Section 92C

AO/TPO erred in rejecting cost plus method (CPM) adopted by the Appellant and selecting Transactional Net Margin Method (TNMM) as the most appropriate method to determine the Arm's Length Price of the transaction of sale of goods to AEs. 1.4. Without prejudice, the Ld. TPO erred in selecting certain ... rejected the segmental accounts of the assessee and also the CPM method selected as the Most Appropriate Method (MAM) for benchmarking the transactions and treating Transactional Net Margin Method (TNMM) as the MAM, he selected comparables and determined their average margin of operating profit to operating cost, OP/OC

Pr. CIT-9, Mumbai vs. E-Clinical Works India Pvt Ltd, Mumbai

In the result, appeal of the Revenue is partly allowed

ITA 4106/MUM/2019[2014-15]Status: DisposedITAT Mumbai31 Jul 2023AY 2014-15

Bench: Us, Ld. Counsel For The Assessee At The Outset Submitted That Even If One Comparable, I.E., M/S. Mps Limited Is Excluded, Then Other Two Comparables Even If They Are Not To Be Included Will Become Purely Academic Because Assessee Would Be Within The Arm’S Length Price.

Section 143(3)

enabled services of Rs.120,42,18,944/-. The assessee 9 E-Clinical Works India Pvt. Ltd. company had applied TNMM as the Most Appropriate Method and submitted its margin on that profit before interest, depreciation and tax upon operating cost at 21.05% and reported that the comparables which assessee

M/S. Raghuveer Metals Industries Ltd., Ajmer vs. ACIT, Central Circle, Alwar

The appeal of the revenue is dismissed and that of the

ITA 297/JPR/2020[2012-13]Status: DisposedITAT Jaipur31 Jul 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 297/JP/2020 fu/kZkj.k o"kZ@Assessment Year : 2012-13 M/s Raghuveer Metals Industries Ltd., 21, Adarsh Nagar, Ajmer cuke Vs. Assistant Commissioner of Income Tax, Central Circle, Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCR 7496 R vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITA No. 1039/JP/2016 fu/kZkj.k o"kZ@Assessment Year : 2012-13 Assistant Commissioner of Income Tax, Ce

For Appellant: Sh. Himanshu Goyal (CA) &For Respondent: Sh. A. S. Nehra (CIT)
Section 143Section 250

manufacturing account for the year under consideration, the past history of gross profit rate of manufacturing account of the assessee was adopted the most appropriate method on perusal of the last two years, GP for manufacturing account reveals that the average rate of GP works out to 0.9 % in respect

ACIT, Alwar vs. Raghuveer Metal Industries Pvt. Ltd., Ajmer

The appeal of the revenue is dismissed and that of the

ITA 1039/JPR/2016[2012-13]Status: DisposedITAT Jaipur31 Jul 2023AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 297/JP/2020 fu/kZkj.k o"kZ@Assessment Year : 2012-13 M/s Raghuveer Metals Industries Ltd., 21, Adarsh Nagar, Ajmer cuke Vs. Assistant Commissioner of Income Tax, Central Circle, Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AABCR 7496 R vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITA No. 1039/JP/2016 fu/kZkj.k o"kZ@Assessment Year : 2012-13 Assistant Commissioner of Income Tax, Ce

For Appellant: Sh. Himanshu Goyal (CA) &For Respondent: Sh. A. S. Nehra (CIT)
Section 143Section 250

manufacturing account for the year under consideration, the past history of gross profit rate of manufacturing account of the assessee was adopted the most appropriate method on perusal of the last two years, GP for manufacturing account reveals that the average rate of GP works out to 0.9 % in respect

Nikon India P.Ltd, Gurgaon vs. ACIT, Circle-3(1), Gurgaon

In the result, the appeal of the assessee is partly allowed and the Stay

ITA 1800/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Jul 2023AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.Assessment Year: 2017-18 & Stay Application No.256/Del/2022 (Ita No.1800/Del/2022) Assessment Year: 2017-18 Nikon India Pvt. Ltd., Vs Acit, Plot No.71, Sector-32, Circle-3(1), Institutional Area, Gurgaon. Gurgaon, Haryana – 122001. Pan: Aaccn5100F (Appellant) (Respondent) Assessee By : Shri Vishal Kalra & Shri Ankit Sahani, Advocates; & Shri Yishu Goel, Ar Revenue By : Shri Rajesh Kumar, Cit-Dr Date Of Hearing : 19.07.2023 Date Of Pronouncement : 27.07.2023 Order Per M. Balaganesh, Am: The Appeal In Ita No.1800/Del/2022 & The Stay Application In Sa No.256/Del/2022 Filed By The Assessee Arise Out Of The Order Of Assessment Passed U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 Sa No.256/Del/2022 (Hereinafter Referred To As ‘The Act’) Dated 25.07.2022 By The Assessment Unit, Of The Income Tax Department (Hereinafter Referred To As ‘Ld. Ao’).

For Appellant: Shri Vishal Kalra &For Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)Section 144C(5)Section 92C

assessee as reflected in Form No.3CEB were fully furnished by the assessee before the ld.TPO duly mentioning the value of transactions and the most appropriate method adopted by the assessee. The ld. TPO observed that the assessee had incurred AMP expenses to the tune of Rs.108,55,75,662/- which