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The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer support services rendered outside India cannot be treated as fees for technical services (FTS). Consequently, no disallowance u/s 40(a)(i) is warranted for non-deduction of tax at source. Regarding transfer pricing adjustments for provision of product development and other IT services, the Tribunal directed the Transfer Pricing Officer (TPO) to include Isummation Technologies Pvt. Ltd., Sagar Soft (India) Ltd., and Yudiz Solution Pvt. Ltd. as comparables and recompute the arm's length price accordingly. For provision of sales and marketing support services, the Tribunal excluded Majestic Research Services and Solutions Ltd. from the list of comparables, directing the TPO to recompute the arm's length price after excluding this company.
The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer support services rendered outside India cannot be treated as fees for technical services (FTS). Consequently, no disallowance u/s 40(a)(i) is warranted for non-deduction of tax at source. Regarding transfer pricing adjustments for provision of product development and other IT services, the Tribunal directed the Transfer Pricing Officer (TPO) to include Isummation Technologies Pvt. Ltd., Sagar Soft (India) Ltd., and Yudiz Solution Pvt. Ltd. as comparables and recompute the arm's length price accordingly. For provision of sales and marketing support services, the Tribunal excluded Majestic Research Services and Solutions Ltd. from the list of comparables, directing the TPO to recompute the arm's length price after excluding this company.
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