Taxpayer's Benchmarking Accepted: License Fees for Software Services Found at Arm's Length, Overruling Initial Nil and Ad Hoc Rs. 50 Lakh Determinations.

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....TP Adjustment to the licence fees paid for time and billing software - Determination of arm's length price at Nil in grounds 1 & 2 and at Rs. 50 lakhs on ad hoc basis in ground 3 is contrary to the provisions of the Act. Resultantly, the benchmarking done by the assessee is more acceptable and the transactions of the assessee with its AE for the services availed is held to be at arm's length. - AT....