M/S. SAVA HEALTHCARE LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX,, PUNE
In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method
ITA 1064/PUN/2017[2009-10]Status: DisposedITAT Pune27 Jun 2019AY 2009-10
Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14
For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)
capital employed based, floor area base, headcount base, etc. He then pointed out that it was a fit case to resort to average allocation ratio i.e. average of assets plus expenses allocation keys and pointed out that the steps to be taken in this regard which are reproduced at page 83 of TPO’s order. The TPO thus, worked
