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of ITAT addressed multiple issues regarding an IT company's tax assessment. The Tribunal left open the determination of whether the assessee operates as a KPO or software developer, citing insufficient reasoning from TPO/DRP. On corporate guarantee fees, ITAT directed benchmarking at 0.53% limited to actual guarantee periods. Regarding TDS under s.192, the matter of salary expense disallowance was remanded to AO for fresh verification of additional evidence submitted by assessee. The Tribunal set aside the 30% disallowance under s.40(a)(ia), directing AO to examine documentation supporting non-deduction of TDS where employee incomes fell below taxable threshold. Case remanded for limited review of salary payments and TDS compliance under s.192.
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