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Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr
transferred to its AE indirectly which amount to transfer of unique intangibles. Therefore, the profit split method will be appropriate method to determine ALP because assessee was not just manufacturer of the product. The AO/TPO further found that learned CIT(A) for AY 2008-09 while upholding the Profit Split Method taken the profit sharing ratio at 80:20 between