Court Revises Transfer Pricing Adjustment for Employee Secondment; Disapproves Benchmarking with Third-Party Agency Rates.

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....TP Adjustment - secondment of employees by Assessee to its AE - the benchmarking done by the TPO by applying the same rate of thirty party placement agency is not correct, since there are additional services/benefits provided by third-party agencies while providing Recruitment Services whereas in Assessee’s case, it is a pure deployment of personnel with regard to software services. Accordingly since there is need for an adjustment for the benefit derived we hold that the TP adjustment is to be revised to Rs.4,00,000/-. This ground of the Revenue is partly allowed. - AT....