Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh
section 92D of the Income-tax Act, 1961 ("the Act') read with Rule 10D of the Income Tax Rules, 1962 ("the Rules")) which clearly demonstrates that the 1.68 percent (of the value of supplies made) profits attributable to the Indian operations with respect to overseas supplies made by Appellant is in compliance with the arm's length principle, as embodied