Internal TNMM preferred over external TNMM considering a higher degree of comparability

Neilsoft Private Limited Vs DCIT (ITAT Pune) This appeal by the assessee is directed against the final assessment order dated 13-04-2021 passed by the Assessing Officer u/s 143(3) r.w.s. 144C(13) r.w.s. 143(3A) & 143(3B) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) in relation to the assessment year 2016-17. 2. The only issue raised through various grounds in this appeal is against the making of transfer pricing adjustment amounting to Rs.1,73,70,067/-. 3. Tersely stated, the facts of the case are that the assessee is an Indian Company engaged mainly in providing ...