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ITAT Bangalore Excludes Four Software Development Comparables in Transfer Pricing Appeal
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Vs ACIT (ITAT Bangalore) The Bangalore ITAT partly allowed the assessee’s appeal against the final assessment order passed under Sections 143(3) read with 144C(13) of the Income-tax Act for AY 2015-16.
The appeal involved transfer pricing adjustments relating to software development services and IT-enabled services rendered to Associated Enterprises (AEs).
During the hearing, the assessee submitted that, with respect to the IT-enabled services segment, a revised order under Section 92CA had accepted the international transactions as being at arm’s length...