International Transaction u/s 92(1) of the Income Tax Act

Last updated: 14 January 2022
Quick Summary
This ITAT Bangalore ruling addresses an appeal concerning international transactions under Section 92(1) of the Income Tax Act for AY 2016-2017. The assessee objected to the Transfer Pricing Officer's (TPO) proposed rejection of their chosen foreign parent company as the tested party for benchmarking software services. The TPO cited Rule 10B(2)(d) regarding market comparability, while the assessee provided counterarguments and case law. The appeal was partly allowed.

Court :
ITAT Bangalore

Brief :
This appeal by the assessee is directed against the final Order of Assessment dated 30.3.2021 by the National E-Assessment Centre, Delhi, (hereinafter referred to as the Assessing Officer, “AO” in short) passed u/s.143(3) read with Section 144C(13) of the Income Tax Act

Citation :
IT(TP)A No.187/Bang/2021

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