Unrelated Transactions Revenue at 20.30% Shouldn't Invalidate Appellant's Internal Comparability Analysis in Software Contracts Case.

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....Transfer price - The revenue derived from unrelated party transactions at 20.30% of the aggregate revenue of the appellant, cannot be the reason for disregarding internal comparability analysis undertaken by the appellant. It would be appreciated that the appellant in the course of its business enters into several software development contracts of small volume. - AT....