ITAT upheld Segregation approach for benchmarking of Contract Software Development Services & ITeS

Orange Business Services India Solutions Pvt. Ltd. Vs DCIT (ITAT Delhi) We have heard rival submission of the parties and perused the orders, including the order of the Tribunal in ITA No. 6928/Del/2017 for assessment year 2013-14. The Tribunal (supra) in para 22nd and 23rd has directed as under: “22. In the first round of litigation, ld. TPO in this case had proceeded to benchmark international transaction qua CSDS and ITES segment by adopting aggregated approach. Now, as per our findings returned in the preceding paras, both the segment i.e. CSDS and ITES are required to be benchmarked ind...