ITAT Deletes ESOP Disallowance but Remands TP Comparables Over Functional Mismatch

SAP India Private Limited Vs DCIT (ITAT Bangalore) SAP India Private Limited filed ITA No. 704/Bangalore/2023 for the assessment year 2019–20 against the assessment order under sections 143(3), 144B, and 144C(13) of the Income Tax Act, 1961, pursuant to the transfer pricing assessment under section 92CA(3) issued by the Deputy Commissioner of Income Tax (Transfer Pricing) and directions from the Dispute Resolution Panel (DRP). The total income initially filed by the assessee was ₹7,901,553,920, revised to ₹7,804,453,360, and assessed at ₹8,423,688,054. Several grounds of appeal were fi...