https://www.taxtmi.com/caselaws?id=412680 The Tribunal partly allowed the appeal, applying MAP resolution to non-US AE transactions for a TP adjustment in providing ITeS. The resolution, initially covering 94% of the adjustment with the US AE, was extended to non-US AEs based on established legal principles and the absence of distinctions in accounts or TP analysis. The Tribunal found merit in the assessee's claim, citing precedent and holding that margins accepted in MAP proceedings with the US AE could guide the ALP for non-US AE transactions. Consequently, the appeal was partly allowed, and further consideration of raised grounds was deemed unnecessary. en-us Fri, 17 Sep 2021 00:00:00 +0530 Fri, 24 Sep 2021 07:18:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412680 The Tribunal partly allowed the appeal, applying MAP resolution to non-US AE transactions for a TP adjustment in providing ITeS. The resolution, initially covering 94% of the adjustment with the US AE, was extended to non-US AEs based on established legal principles and the absence of distinctions in accounts or TP analysis. The Tribunal found merit in the assessee's claim, citing precedent and holding that margins accepted in MAP proceedings with the US AE could guide the ALP for non-US AE transactions. Consequently, the appeal was partly allowed, and further consideration of raised grounds was deemed unnecessary. Case-Laws Income Tax Fri, 17 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412680