Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
The ITAT held that protective additions made by the AO concerning payments for information & technology fees and commission on sales were not tenable. Since the assessee had already settled these disputes with the competent authority under MAP and accepted the adjustments made by the TPO, no further disallowance u/s 37 was required to be sustained on a protective basis for the relevant assessment years. The assessee's appeals were allowed.
The ITAT held that protective additions made by the AO concerning payments for information & technology fees and commission on sales were not tenable. Since the assessee had already settled these disputes with the competent authority under MAP and accepted the adjustments made by the TPO, no further disallowance u/s 37 was required to be sustained on a protective basis for the relevant assessment years. The assessee's appeals were allowed.
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