https://www.taxtmi.com/caselaws?id=460873 ITAT Delhi ruled on multiple issues in this BPO services case. For transfer pricing adjustments, the tribunal directed adoption of net profit margins of 14.99% (AY 2010-11) and 15.01% (AY 2011-12) for non-USA/UK countries, applying the same rates agreed under MAP for USA/UK transactions. Prior period expenses issue was restored to AO for verification. Section 10A deduction was allowed after deducting telecommunication expenses from both export and total turnover. TDS credit claim was restored to AO for verification. Gain on share buyback was held taxable as capital gains, not deemed dividend under section 2(22)(d). Assessee's appeal was partly allowed; revenue's appeal was dismissed. en-us Mon, 04 Feb 2019 00:00:00 +0530 Wed, 26 Feb 2025 22:24:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460873 ITAT Delhi ruled on multiple issues in this BPO services case. For transfer pricing adjustments, the tribunal directed adoption of net profit margins of 14.99% (AY 2010-11) and 15.01% (AY 2011-12) for non-USA/UK countries, applying the same rates agreed under MAP for USA/UK transactions. Prior period expenses issue was restored to AO for verification. Section 10A deduction was allowed after deducting telecommunication expenses from both export and total turnover. TDS credit claim was restored to AO for verification. Gain on share buyback was held taxable as capital gains, not deemed dividend under section 2(22)(d). Assessee's appeal was partly allowed; revenue's appeal was dismissed. Case-Laws Income Tax Mon, 04 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460873