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ITAT allowed the appeal in part. It held that the assessee's application of TNMM with a median margin (6.32%) and reliance on 13 comparables was not rebutted by the TPO, and that existence of a Master Services Agreement and continuous provision of 24/7 support and onsite services by the AE precluded treating the international transaction as at non-arm's length or at Nil ALP; the TP adjustment by AO/TPO was quashed. ITAT observed that denial of deduction for payments invoiced by the AE cannot be sustained merely for lack of a separate work order. With regard to PF/ESI disallowance, ITAT directed the AO to verify whether the assessee had made a suo motu disallowance and, if double disallowance is found, to delete the addition.
ITAT allowed the appeal in part. It held that the assessee's application of TNMM with a median margin (6.32%) and reliance on 13 comparables was not rebutted by the TPO, and that existence of a Master Services Agreement and continuous provision of 24/7 support and onsite services by the AE precluded treating the international transaction as at non-arm's length or at Nil ALP; the TP adjustment by AO/TPO was quashed. ITAT observed that denial of deduction for payments invoiced by the AE cannot be sustained merely for lack of a separate work order. With regard to PF/ESI disallowance, ITAT directed the AO to verify whether the assessee had made a suo motu disallowance and, if double disallowance is found, to delete the addition.
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