AdvertisementSAS Research and Development (India) Private Limited Vs additional / Joint / Deputy/ACIT/ITO (ITAT Pune) The Pune ITAT partly allowed the assessee’s appeal against the assessment order passed under Sections 143(3), 144C(13), 143(3A) and 143(3B) of the Income-tax Act for AY 2016-17. The dispute arose from a transfer pricing adjustment relating to software development support, consultancy and training services rendered by the assessee to its Associated Enterprises (AEs). The assessee had benchmarked its international transactions under the Transactional Net Margin Method (TNMM), which was ...