https://www.taxtmi.com/caselaws?id=755411 The ITAT Bangalore remanded multiple transfer pricing issues to the AO/TPO for fresh determination. The tribunal directed examination of APA applicability for IT services, exclusion of three comparables deemed unfit for a captive service provider, and separate benchmarking of distribution segment using TNMM. The assessee was held not to be a dependent agent permanent establishment of Google Ireland, rejecting royalty/FTS treatment of payments. Section 10A deduction computation was remanded following SC precedent. Book rejection was overturned due to lack of discrepancies. ITeS segment deduction eligibility requires verification of foreign currency receipts and supporting documentation. en-us Fri, 22 Dec 2023 00:00:00 +0530 Fri, 12 Jul 2024 07:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755411 The ITAT Bangalore remanded multiple transfer pricing issues to the AO/TPO for fresh determination. The tribunal directed examination of APA applicability for IT services, exclusion of three comparables deemed unfit for a captive service provider, and separate benchmarking of distribution segment using TNMM. The assessee was held not to be a dependent agent permanent establishment of Google Ireland, rejecting royalty/FTS treatment of payments. Section 10A deduction computation was remanded following SC precedent. Book rejection was overturned due to lack of discrepancies. ITeS segment deduction eligibility requires verification of foreign currency receipts and supporting documentation. Case-Laws Income Tax Fri, 22 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755411