https://www.taxtmi.com/caselaws?id=776696 The ITAT Pune upheld the DRP's rejection of the assessee's claim to apply internal TNMM for Staff Augmentation services, noting significant functional differences between export and domestic services. The tribunal excluded Interactive Manpower Solution Pvt. Ltd. from the comparable set due to differing NIC/ITC codes and abnormal profit margins, directing the AO to recalculate the weighted average margin without it. For Software Development services, the tribunal found no need for alternate ALP adjustment as the operating profit margin was within the comparable range. The final ALP for Staff Augmentation services was to be determined using the median margin of the two remaining comparables, resulting in a recalculated profit margin of 2.37% versus the assessee's reported 5.52%. The AO was directed to give effect accordingly. en-us Fri, 18 Jul 2025 00:00:00 +0530 Sat, 16 Aug 2025 10:11:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776696 The ITAT Pune upheld the DRP's rejection of the assessee's claim to apply internal TNMM for Staff Augmentation services, noting significant functional differences between export and domestic services. The tribunal excluded Interactive Manpower Solution Pvt. Ltd. from the comparable set due to differing NIC/ITC codes and abnormal profit margins, directing the AO to recalculate the weighted average margin without it. For Software Development services, the tribunal found no need for alternate ALP adjustment as the operating profit margin was within the comparable range. The final ALP for Staff Augmentation services was to be determined using the median margin of the two remaining comparables, resulting in a recalculated profit margin of 2.37% versus the assessee's reported 5.52%. The AO was directed to give effect accordingly. Case-Laws Income Tax Fri, 18 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776696