Additional evidence concerning global IT services payments was...

Additional evidence concerning global IT services payments was admitted because third-party invoices and service-allocation details addressed the basis of the transfer pricing adjustment; the issue was remitted to the AO/TPO for fresh examination. The AO was directed to verify and give effect to the deduction claim under section 80JJAA in accordance with DRP directions. TDS credit was also remitted for verification and grant of due credit. Claims challenging the fee under section 234F, based on filing within the extended due date, and seeking recomputation of interest under section 244A were restored to the AO for factual verification and disposal according to law. The appeal was partly allowed for statistical purposes.