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ITAT Bangalore directed AO to apply MAP rate on International Transactions
Case Law Details
- Case Name
- Conduent Business Services India LLP Vs ACIT (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
- Courts
- All ITAT, ITAT Bangalore
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Conduent Business Services India LLP Vs ACIT (ITAT Bangalore)
Conclusion: MAP rate should be applied by AO/TPO for the rest of the transitions of Rs.25,09,87,512 which was 4.42% of the total transactions. Accordingly, AO was directed to apply the MAP rate on the rest of the transactions for determination of the margin on the international transactions.
Held: Assessee was engaged in 2 segments software development services , IT Enabled Services and Marketing Support Services during the impugned assessment year to US affiliate Companies and Non-US affiliate Companies. Assessee s...
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