https://www.taxtmi.com/caselaws?id=300421 The High Court remanded the case back to the Tribunal to re-examine whether the taxpayer was engaged in both IT services and ITES, based on additional evidence. The Tribunal found the taxpayer was involved in Contract Software Development Services (CSDS) and ITES. The Tribunal directed the TPO to independently benchmark the international transactions of both segments and allocate common expenses using the "head count" method. The case was remanded for fresh determination of the Arm's Length Price (ALP) for both segments, allowing both parties an opportunity to present their arguments. en-us Thu, 15 Jul 2021 00:00:00 +0530 Mon, 31 Jan 2022 21:09:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=300421 The High Court remanded the case back to the Tribunal to re-examine whether the taxpayer was engaged in both IT services and ITES, based on additional evidence. The Tribunal found the taxpayer was involved in Contract Software Development Services (CSDS) and ITES. The Tribunal directed the TPO to independently benchmark the international transactions of both segments and allocate common expenses using the "head count" method. The case was remanded for fresh determination of the Arm's Length Price (ALP) for both segments, allowing both parties an opportunity to present their arguments. Case-Laws Income Tax Thu, 15 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=300421