BAHWAN CYBERTEK PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeal is partly allowed

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./Ita No.290/Mds/2017 "नधा"रण वष" / Assessment Year : 2012-13

44C is not invoked here but only an inference is drawn to determine an appropriate revenue apportionment ratio between the Assessee and the AE. Considering the functions of the AE with regard to the transactions with the assessee, 5% of the total 7 Bahwan CyberTek Pvt. Ltd. v. Asst. CIT income from such transaction may be allocated in respect