2026 (6) TMI 605

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....For the Assessee : Mr. B Ramakrishnan - CA & Ms. M.Lavanya - CA For the Revenue : Mr. ARV Sreenivasan - CIT(DR) ORDER PER INTURI RAMA RAO, AM : This is an appeal filed by the assessee directed against the final assessment order of Assessment Unit, Income Tax Department dated 29.12.2025 passed under section 143(3) r.w.s 144C(3) read with section 144B of the Income Tax Act, 1961 for A.Y.....

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.... by submitting the TP study, wherein the assessee company had adopted Transactional Net Margin Method(TNMM) as the most appropriate method. On noticing the above international transactions, the Assessing Officer referred the matter to the TPO for the purpose of benchmarking the above international transactions, u/s. 92CA of the Act. The TPO vide order dated 22.01.2025 passed u/s. 92CA(3) of the In....

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.... 5. Being aggrieved by the final assessment order, the appellant is in appeal before us in the present appeal. At the outset, we find that the appellant company had characterized its services as ITES Company whereas, the TPO sought to benchmark the international transaction by adopting the comparable which are into the software development services, therefore, we are of the considered opinion tha....